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Governing Board Meeting Materials
August 26, 2020, 10:00 a.m.
Agenda
BOARD MEETING AGENDA
August 26, 2020 – 10:00 a.m.
Meeting Registration: https://attendee.gotowebinar.com/register/4054637552031767564 Audio: If you will not be using computer audio controls, a dial-in number will be provided by
GoToWebinar.com once you click “register” on the meeting application.
I. Public Comment Period**
II. Approve Meeting Minutes (Action Item) III. Chairman’s Report
- Education and Outreach Update - Schedule for 2020 and 2021
IV. Executive Committee Report
- Water Resource Management Plan Amendments o Coweta County Water Authority (Action Item) o Villa Rica, GA o Action Items
- 2021 Budget Revision (Action Item) - 2022 Water Resource Management Plan Consultant Contract (Action Item)
V. Water Supply Status / Litigation Update
VI. Special Presentation
VII. Adjourn
**A 10-minute period for public comments is designated as needed at each Governing Board meeting during a time deemed appropriate by the Chairman. Each speaker must sign-up at least two (2) days prior to the meeting start time by emailing Chairman@northgeorgiawater.com. The 10 minute period will be divided by the number of people wishing to address the Board. No single speaker shall have more than five (5) minutes to address the Board. Comments should also be provided in writing, with supporting material. The Chairman reserves the right to limit or extend the speaking time or total number of speakers at any meeting.
Meeting Minutes
Metropolitan North Georgia Water Planning District
GOVERNING BOARD Minutes
May 27, 2020 The Metropolitan North Georgia Water Planning District Governing Board met on Wednesday, May 27, 2020 at 10:00 a.m. through an online web-conference.
Members Present Ms. Katie Kirkpatrick, Vice Chair Clayton County Designee: Mr. Bernard Franks Mr. Birdel Jackson, Treasurer Cobb County Designee: Mr. Eric Olson Hon. Harry Johnston Coweta County Designee: Mr. Jay Boren Dr. Mark Berry Douglas County Designee: Mr. Gil Shearouse Ms. Pamela Burnett Fayette County Designee: Ms. Vanessa Tigert Mr. Brad Currey Forsyth County Designee: Mr. Tim Perkins Ms. Kit Dunlap Fulton County Designee: Mr. Nick Ammons Mr. Glenn Page Gwinnett County Designee: Mr. Kevin Farrell Mr. Gerald Pouncey Paulding County Designee: Mr. Boyd Austin Mr. Tim Thoms Hall County Designee: Ms. Linda MacGregor Henry County Designee: Mr. Tony Carnell
Members Not Present Hon. Keisha Lance Bottoms Hon. Michael Thurmond Hon. Steve Taylor Hon. Oz Nesbitt
Vice Chair Katie Kirkpatrick called the meeting to order.
Vice Chair Kirkpatrick presented the December 4, 2019 Board meeting minutes for approval. A motion to approve the meeting minutes was made by Mr. Bernard Franks. The motion was seconded by Dr. Mark Berry and passed without opposition.
Mr. Danny Johnson presented an overview of the 2019 Comprehensive Annual Report and Audit.
Vice Chair Kirkpatrick presented the remaining schedule of Board meeting dates for 2020.
Vice Chair Kirkpatrick announced that 21 applicants for Basin Advisory Council (BAC) membership were approved during the Executive Committee meeting.
Metropolitan North Georgia Water Planning District May 27, 2020 Governing Board Meeting Minutes Page 2 Mr. Birdel Jackson presented the 2020 Budget Revision for approval. Mr. Jackson made a motion to approve the 2020 Budget Revision. The motion was seconded by Dr. Berry and passed without opposition.
Mr. Birdel Jackson presented the 2021 Budget and Work Program for approval. A board member requested that the line item for State Appropriations be increased from $0 to $172,000. A motion to table the action was made by Mr. Boyd Austin. The motion was seconded by Ms. Pam Burnett and passed without opposition.
Vice Chair Kirkpatrick requested that in light of current COVID-19 conditions & decreased revenues for some counties, the District should evaluate action items that may have become outdated or no longer fit our present circumstances to see whether any make sense to be amended.
Mr. Glenn Page requested that the District review the proposed scope of work for the Water Resource Management Plan Update and consider including a forecast for water plant residuals alongside the forecast for wastewater biosolids.
Mr. Andrew Morris presented a proposal regarding small community plan implementation. Mr. Austin presented the Nominating Committee’s recommendations for the District Chair, Vice Chair, and Secretary/Treasurer. The committee recommended Mr. Glenn Page as Chair, Ms. Katie Kirkpatrick as Vice Chair, and Dr. Mark Berry as Secretary/Treasurer. A motion to approve the slate of board members for election was made by Mr. Austin. The motion was seconded by Mr. Gil Shearouse and passed without opposition.
Ms. Katherine Zitsch presented an overview of water supply conditions, near term forecasts, and litigation status.
Ms. Justine Schwartz presented the winners of the 2020 High School Video Contest. This year’s winners for both the English and Spanish contests included:
1st Place Winner – English - Lihee Freeman – Alpharetta High School, Fulton County 1st Place Winner – Spanish - Itandehui Cruz – Heritage High School, Rockdale County 2nd Place Winner – English - Reece Moseley – Mill Creek High School, Gwinnett County 2nd Place Winner – Spanish - Jayasri Mankan – South Forsyth High School, Forsyth County
There being no further business, Vice Chair Kirkpatrick adjourned the meeting.
Metropolitan North Georgia Water Planning District
GOVERNING BOARD Minutes
June 8, 2020 The Metropolitan North Georgia Water Planning District Governing Board met on Monday, June 8, 2020 at 9:00 a.m. through an online web-conference.
Members Present Hon. Charlotte Nash, Chair City of Atlanta Designee: Ms. Mikita Browning Ms. Katie Kirkpatrick, Vice Chair Clayton County Designee: Mr. Bernard Franks Mr. Birdel Jackson, Treasurer Cobb County Designee: Mr. Eric Olson Hon. Harry Johnston Douglas County Designee: Mr. Gil Shearouse Hon. Randy Ognio Forsyth County Designee: Mr. Tim Perkins Dr. Mark Berry Hall County Designee: Ms. Linda MacGregor Ms. Pamela Burnett Henry County Designee: Mr. Tony Carnell Ms. Kit Dunlap Mr. Glenn Page Mr. Tim Thoms
Members Not Present Hon. Steve Taylor Hon. David Carmichael Hon. Paul Poole Hon. Oz Nesbitt Hon. Michael Thurmond Mr. Brad Currey Hon. Robb Pitts Mr. Gerald Pouncey
Chairman Charlotte Nash called the meeting to order.
Mr. Birdel Jackson presented the 2021 Budget and Work Program for approval. Mr. Jackson made a motion to approve the 2021 Budget and Work Program. The motion was seconded by Ms. Kit Dunlap. The motion passed with fifteen members voting to approve and Hon. Randy Ognio and Mr. Eric Olson voting in opposition.
Mr. Andrew Morris presented a proposal regarding possible amendments to the District’s Water Resource Management Plan during the COVID pandemic.
There being no further business, Chairman Nash adjourned the meeting.
Coweta County Water Authority Amendment
Request
TO: Executive Committee FROM: Metro Water District Staff DATE: August 14, 2020 RE: Plan Amendment Process Documentation and Staff Recommendation
Coweta County Water and Sewerage Authority ________________________________________________________________________ The Metropolitan North Georgia Water Planning District received a request from the Coweta County Water and Sewerage Authority (the Authority) to modify the Water Resource Management Plan. The Executive Committee met on December 4, 2019 and categorized the proposed changes as a major amendment pursuant to the District’s “Plan Amendment Guidelines” and initiated a 30-day public review and comment period. The District solicited public review and comment on the proposed amendment from April 16, 2020 to May 16, 2020. The public review and comment period was advertised in the Fulton County Daily Report on April 15, 2020 (copy of the announcement and published notice), on the District’s website throughout the period, and by notice to the District’s Technical Coordinating Committee and Basin Advisory Councils sent via email (attached). Amendment Request: Appendix B, Coweta County – Water and Wastewater
Appendix B, Fulton County - Water Local Jurisdiction: Coweta County Description: The Authority requests that Appendix B, Coweta County -
Water be revised to include an expanded water supply capacity from the Chattahoochee River and the BT Brown Reservoir, an increased capacity for the BT Brown Water Treatment Plant, and a reduction in future water supply needs from Fulton County sources to Coweta County. The amendment request reflects a change in the water supply source location on the Chattahoochee River to move from an external water supplier to an intake owned and operated by CCWSA. The request does not affect the District’s demand forecast for the region or ACF basin. Additional amendment
2
background and details are provided in the attached letter from CCWSA dated April 9, 2020.
Comment Summary: The District received four comment letters on the proposed
amendment. The letters are attached. The Authority’s response to these comments is also attached. District staff believe that the Authority’s response appropriately addresses the comments received. In addition, District staff have considered comments by the State of Alabama that the proposed amendment, if granted, would undermine environmental studies by the US Army Corps of Engineers supporting its 2017 decision to meet the year 2050 water supply demands of the District jurisdictions from the Chattahoochee River and Lake Lanier. Alabama’s comments regarding the validity of the Corps’ environmental studies are unfounded. Alabama uses an approach that is not technically sound in order to drastically overstate the effects of the proposed amendment. Given the size and location of the proposed withdrawal, District staff can say with a high degree of confidence that the proposed amendment would have a negligible effect on stream flows and an imperceptible impact on lake levels at the Corps reservoirs, including both West Point and Lake Lanier. This understanding is informed by Staff’s detailed understanding of the Corps’ basin-wide operations and extensive prior modeling work examining the effects of operational changes and water supply demands in the ACF Basin. Alabama suggests that the proposed amendment calls into question the validity of the Corps’ Environmental Impact Statement. As shown in the Authority’s response to comments, the withdrawal reflected in the proposed amendment will have an almost imperceptible impact on stream flows, even during the worst drought in the basin’s history, and a negligible effect at the basin scale. There is nothing to suggest that the Corps’ determination would have been different if this small additional withdrawal were considered, or that water supply operations at Lake Lanier would need to be revisited as a result of this amendment. Alabama’s comments and its supporting technical analysis are based entirely on a reported flow in the Chattahoochee River upstream of West Point Lake for a single month (August 2007) during the critical drought for the ACF Basin. The flow Alabama relies upon was obtained from the Corps’ Res-Sim model prepared in connection with the Corps’ update to the ACF Master Water Control Manual.
3
Alabama then runs a spreadsheet calculation to show the supposed impact downstream. But, Corps operating procedures have changed since the 2007 drought. Furthermore, impacts to Alabama would occur on the lake itself, not upstream at the river. To depict the true effects of the proposed amendment, it would be necessary to show the impacts that would occur if the proposed withdrawals occurred under the current operating rules for the Corps’ ACF Basin reservoirs, which it operates as a system to meet various basin needs. This requires the use of a hydrologic model, such as the Corps’ Res-Sim model. Alabama has the capability to run the Corps’ Res-Sim model and depict the effects of various withdrawal scenarios using the Corps’ basin-wide operations. It has done so many times during its protracted dispute with the Corps and Georgia over water supply uses in the ACF and ACT Basins. In its comments to the District, however, Alabama declined to submit the Res-Sim model output showing the effects of the proposed amendment. Instead, as discussed above, it has opted to base its comments entirely on a single monthly flow extracted from the model, which it then extrapolates in a manner that drastically overstates the impacts of the proposed amendment. As noted above, District staff are confident the proposed amendment would have a negligible effect on stream flows and an imperceptible impact on lake levels at the Corps reservoirs, including both West Point and Lake Lanier. Alabama’s failure to submit the full model results supports this conclusion.
Staff Recommendation: Recommend that the plan be amended as requested. This project adds needed resilience to the southern portion of the region. Further, it maximizes the use of the existing BT Brown Reservoir and related infrastructure.
Coweta County Water Authority – WRM Amendment Request
Coweta County Water Authority Amendment Request Contents:
1) Proposed Changes to Appendix B
2) April 9, 2020 Amendment Request Letter
3) Public Comment Period Notice
4) August 13, 2020 Public Comment Response Letter
5) Public Comments Received
6) Letter of Support from Coweta Co Delegation Members
Coweta County Water Authority – WRM Amendment Request
Proposed Changes to Appendix B
1) Appendix B – Coweta Water
2) Appendix B – Fulton Water
3) Appendix B – Coweta Wastewater
Coweta County ‐ Water
Summary of Planned Sources
Monthly (Note 1) Peak Day
CCWSA 7.5 10.0
CCWSA 7.5 10.0
Newnan
Newnan
Newnan
Newnan
Senoia 0.34 0.45
Crystalline Rock Aquifer CCWSA 0.504 0.504
Crystalline Rock Aquifer Senoia 0.233 0.233
30.0 39.8
Summary of Needs
Scenario 1 Scenario 2 Scenario 1 Scenario 2
27.8 25.6 38.0 37.6
‐1.8 ‐1.8 ‐1.4 ‐1.4
16.0 13.8 26.6 26.2
Scenario 1
2025 (AAD‐MGD)
Scenario 2
2025 (AAD‐MGD)
Scenario 1
2050 (AAD‐MGD)
Scenario 2
2050 (AAD‐MGD)
10.0 8.7 16.6 16.4
Notes:
(2) Peak day is 1.6 times annual average day.
Phasing Plan
Coweta B.T. Brown WTP
Newnan Hershall Norred WTP
Senoia WTP (Note 7)
Coweta County
Senoia
Total Capacity (PD‐MGD)
Notes:
Capital Projects
Non‐Capital Programs
0.233
A water intake pump station and force main to convey water from the Chattahoochee River to the B.T. Brown Reservoir
(6) The schedule shown above is intended to be a general guideline to identify general expansion needs. Expansion capacity may be required
sooner or later than indicated depending on local population and employment growth, water service extensions and other planning variables.
Specific conditions for withdrawal and operation permits will be determined by Georgia EPD.
Chattahoochee River 0
(3) Coweta County Water and Sewer Authority (CCWSA) is seeking a permit from Georgia EPD to have a direct withdrawal from the Chattahoochee
River. If that water withdrawal is permitted and constructed, CCWSA would no longer purchase from the City of Atlanta. In either scenario, total
withdrawals from the Chattahoochee will not be affected.
2025 Peak Day (Note 2)
(PD–MGD)
2050 Peak Day (Note 2)
(PD–MGD)
14.0
Sandy Brown Creek
Total Withdrawal (MGD) 21.7
Notes:
White Oak Creek (Flint River)
Line Creek (Flint River)
18.6
The B.T. Brown WTP should be expanded to 20 PDD‐MGD to fully utilize the yield of B.T. Brown Reservoir.
(7) The City of Senoia has a withdrawal permit with a monthly limit of 0.3 MGD from Hutchin's Lake and a WTP with a total capacity of 0.45 MGD‐
PD. The City will need to increase their water withdrawal permit in order to fully utilize the plant capacity.
Maintain interconnections and water supply agreements with City of Atlanta and City of Griffin.
14.0 14.0 18.6
The following non‐capital programs are specific to Coweta County. These programs are in addition to those that apply to all counties within the
Metro Water District.
Groundwater
21.6 25.2 39.8
0.504 0.504 0.504
0.233 0.233
Total Projected Demand from Facilities (PD‐MGD)
0.45 0.45 0.45
Treatment Capacity (Note 5) 25.2 39.8
Chattahoochee Basin
6.4 10.0 20.0
Chattahoochee/Flint Basins
Flint Basin
(4) The Still Branch Creek Reservoir is located outside of the District and is owned by the City of Griffin in Spalding County. The reservoir serves Pike
and Spalding Counties as well as Coweta County. Coweta County has a purchase contract for 3.0 PDD‐MGD of finished water (2008) from the City of
Griffin which increases to 5.0 PDD‐MGD on July 1, 2022.
Total Projected Demand from Facilities (AAD‐MGD)
(5) Scenario 1 is being used for the phasing plan below.
Facilities (Note 6)
Existing (2016) By 2025 By 2050
Permitted Plant Capacity
(PD‐MGD)
Plant Capacity at End of Period
(PD‐MGD)
Plant Capacity at End of Period
(PD‐MGD)
14.0
J.T. Haynes Reservoir
0.504
Source
Local Water
Provider
Current Permitted Withdrawal
Monthly Average (MGD)
Planned 2050 Withdrawal (MGD)
6.7B.T. Brown Reservoir
Fill J.T. Haynes
Reservoir only
From Fulton County (Note 3) ‐5.0 ‐10.0
From Griffin's Still Branch Reservoir (Note 4)
Hutchins' Lake (Keg Creek) 0.3
‐5.0 0.0
Self Supplied
(1) Monthly average day is 1.2 times annual average day.
Water Demands & Capacities
0.233
Coweta County Needs
PAGE 12
JUNE 2017WATER RESOURCE MANAGEMENT PLAN
METROPOLITAN NORTH GEORGIA WATER PLANNING DISTRICT
Current Version
Page 1 of 2
Coweta County - Water Draft Amendment4/15/2020
Summary of Planned Sources
Monthly (Note 1) Peak Day
CCWSA 22.1 26.9
CCWSA21.3 21.3
Newnan
Newnan
Newnan
Newnan
Senoia 0.34 0.45
Crystalline Rock Aquifer CCWSA 0.504 0.504
Crystalline Rock Aquifer Senoia 0.233 0.233
37.1 46.7
Summary of Needs
Scenario 1 Scenario 2 Scenario 1 Scenario 2
27.8 25.6 38.0 37.6
-1.8 -1.8 -1.4 -1.4
21.0 18.8 36.6 36.2
Scenario 1
2025 (AAD-MGD)
Scenario 2
2025 (AAD-MGD)
Scenario 1
2050 (AAD-MGD)
Scenario 2
2050 (AAD-MGD)13.1 11.8 22.9 22.6
Notes:
(3) Peak day is 1.6 times annual average day.
Phasing Plan
Coweta B.T. Brown WTP
Newnan Hershall Norred WTP
Senoia WTP (Note 8)
Coweta County
Senoia
Total Capacity (PD-MGD)
Notes:(7) The schedule shown above is intended to be a general guideline to identify general expansion needs. Expansion capacity may be required sooner
or later than indicated depending on local population and employment growth, water service extensions and other planning variables. Specific
conditions for withdrawal and operation permits will be determined by Georgia EPD.
(4) Coweta County Water and Sewer Authority (CCWSA) is seeking a permit from Georgia EPD to have a direct withdrawal from the Chattahoochee
River. If that water withdrawal is permitted and constructed, CCWSA would no longer purchase from the City of Atlanta. In either scenario, total
withdrawals from the Chattahoochee will not be affected. In the event that a withdrawal permit is obtained, the connection with the City of Atlanta
will be maintained for emergency service.
2025 Peak Day (Note 3)
(PD–MGD)
2050 Peak Day (Note 3)
(PD–MGD)
(8) The City of Senoia has a withdrawal permit with a monthly limit of 0.3 MGD from Hutchin's Lake and a WTP with a total capacity of 0.45 MGD-PD.
The City will need to increase their water withdrawal permit in order to fully utilize the plant capacity.
Chattahoochee/Flint Basins
(5) The Still Branch Creek Reservoir is located outside of the District and is owned by the City of Griffin in Spalding County. The reservoir serves Pike
and Spalding Counties as well as Coweta County. Coweta County has a purchase contract for 3.0 PDD-MGD of finished water (2008) from the City of
Griffin which increases to 5.0 PDD-MGD on July 1, 2022.
Total Projected Demand from Facilities (AAD-MGD)
(6) Scenario 1 is being used for the phasing plan below.
Treatment Capacity (Note 6) 32.7 46.7
Chattahoochee Basin
6.4
Total Withdrawal (MGD) 21.7
Notes:
White Oak Creek (Flint River)
Line Creek (Flint River)
18.6
14.0 14.0 18.6
Groundwater
21.6 32.7 46.7
0.504 0.504 0.504
0.233 0.233
Flint Basin
17.5 26.9
14.0
J.T. Haynes Reservoir
0.504
Fill J.T. Haynes
Reservoir only
0.0
Facilities (Note 7)
Existing (2016) By 2025 By 2050Permitted Plant Capacity
(PD-MGD)
Plant Capacity at End of Period
(PD-MGD)
Plant Capacity at End of Period
(PD-MGD)
Total Projected Demand from Facilities (PD-MGD)
Sandy Brown Creek
Source
Local Water
Provider
Current Permitted Withdrawal
Monthly Average (MGD)
Planned 2050 Withdrawal (MGD)
6.7B.T. Brown Reservoir (Note 9, 10, 11)
0 Chattahoochee River to BT Brown Res.
(Note 2, 11)
Hutchins' Lake (Keg Creek) 0.3
-5.0
Self Supplied
(1) Monthly average day is 1.2 times annual average day.
Water Demands & Capacities
0.233
Coweta County Needs
(2) The Chattahoochee River pump rate of 21.3 MGD for 2050 is required to help fill the BT Brown Reservoir. This withdrawal is not additive and is
thus not included in the Total Withdrawal for Coweta County.
From Fulton County (Note 4) 0.0 0.0
From Griffin's Still Branch Reservoir (Note 5)
14.0
0.45 0.45 0.45
0.233
PAGE 12
JUNE 2017WATER RESOURCE MANAGEMENT PLAN
METROPOLITAN NORTH GEORGIA WATER PLANNING DISTRICT
Page 2 of 2
Capital Projects
Non-Capital Programs
A water intake pump station and force main to convey water from the Chattahoochee River to the B.T. Brown Reservoir shall be constructed to carry
21.3 MGD by year 2050. The buildout will be conpleted in phases.
The B.T. Brown WTP should be expanded to 26.9 PDD-MGD by 2050 to fully utilize the yield of B.T. Brown Reservoir.
Maintain interconnections and water supply agreements with City of Atlanta and City of Griffin.
The following non-capital programs are specific to Coweta County. These programs are in addition to those that apply to all counties within the
Metro Water District.
(9) The BT Brown Reservoir and pumping system will be capable of providing 26.9 MGD at 2050. The intake in the Chattahoochee River will have the
capacity to pump at a peak rate of 21.3 MGD at 2050. The buildout capacity will be constructed in phases as demands increase.”
(11) The withdrawals from the Chattahoochee River and BT Brown are to serve as a replacement for an existing water source from a small tributary
of the Chattahoochee River, which has proven its inability as a resilient water source in most recent droughts of record. This proposed Chattahoochee
River withdrawal will allow the Authority to supply demands previously served by outside water providers and increase the resilience of its water
supply.
(10) The withdrawal from the Chattahoochee River is to be pumped into BT Brown Reservoir for storage prior to treatment. The withdrawal from BT
Brown Reservoir is taking water previously removed from the Chattahoochee River for treatment.
PAGE 12
JUNE 2017WATER RESOURCE MANAGEMENT PLAN
METROPOLITAN NORTH GEORGIA WATER PLANNING DISTRICT
Fulton County ‐ Water
Summary of Planned Sources
Monthly (Note 1) Peak Day
Atlanta/Fulton 105.0 140.0
Atlanta 180.0 240.0
Roswell 3.8 5.0
East Point 11.6 15.5
Palmetto 0.45 0.6
College Park 0.1670 0.1670
Roswell 0.1670 0.1670
301.2 401.4
Notes:
Summary of Needs
Scenario 1 Scenario 2 Scenario 1 Scenario 2
248.5 266.2 298.2 363.9
‐1.21 ‐1.21 ‐1.01 ‐1.01
252.3 270.0 307.2 372.9
Scenario 1
2025 (AAD‐MGD)
Scenario 2
2025 (AAD‐MGD)
Scenario 1
2050 (AAD‐MGD)
Scenario 2
2050 (AAD‐MGD)
Notes: 155.3 166.4 186.4 227.4
Phasing Plan
Atlanta‐Fulton County WTP
Atlanta Hemphill WTP
Atlanta Chattahoochee WTP
Roswell Cecil Wood WTP (Note 7)
East Point WTP
Palmetto WTP
Roswell
College Park
Total Capacity (PD‐MGD)
Notes:
Capital Projects
Non‐Capital Programs
401.4
(3) Peak day is 1.6 times annual average day.
To Coweta County 10.0
285.1
(2) The Bear Creek Reservoir is currently planned by the proposed South Fulton Municipal Regional Water and Sewer Authority, with an estimated yield
of 16.44 AAD‐MGD. It would withdraw from the Chattahoochee River below Peachtree Creek. If constructed, it would supplement and offset water
supply needs for Fulton County.
Water Demands & Capacities
2025 Peak Day (Note 3)
(PD–MGD)
2050 Peak Day (Note 3)
(PD–MGD)
Fulton County Needs (Note 4)
Self Supplied
Total Projected Demand from Facilities (PD‐MGD)
Total Projected Demand from Facilities (AAD‐MGD)
(4) Demand and capacity are based on the combined total demand and capacity for Futon County as a whole. No attempt was made to analyze demand
by individual service provider within Fulton County or to consider existing service areas and previous bonding commitments associated with the
development of the existing infrastructure.
64.9
Chattahoochee Basin
90.0 90.0 140.0
136.5
Facilities (Note 6)
Existing (2016)Permitted Plant Capacity
(PD‐MGD)
(5) Scenario 2 is being used for the phasing plan below.
Plant Capacity at End of Period
(PD‐MGD)
Plant Capacity at End of Period
(PD‐MGD)
By 2025 By 2050
136.5
0.167 0.167 0.167
64.9
5.0
15.5
0.6
3.0
13.9
0.6
3.0
13.9
0.6
240.0
Groundwater
0.167
401.4
The infrastructure to provide water to Fayette and Clayton Counties on a peak emergency basis should be maintained and expanded as necessary.
Evaluate required improvements to accommodate routine sale of 10 PDD‐MGD to Coweta County.
The following non‐capital programs are specific to Fulton County. These programs are in addition to those that apply to all counties within the Metro
Water District.
Maintain interconnections and water supply agreements with Clayton, Fayette, Coweta, DeKalb, Cobb, Forsyth, and Gwinnett Counties.
Future expansion should be concentrated at the Atlanta‐Fulton County WTP because the intake is located at an upstream location and has an off‐line
reservoir that improves its reliability.
The City of Atlanta should provide 10 PDD‐MGD of water to Coweta County.
(6) The schedule shown above is intended to be a general guideline to identify general expansion needs. Expansion capacity may be required sooner or
later than indicated depending on local population and employment growth, water service extensions and other planning variables. Specific conditions
for withdrawal and operation permits will be determined by Georgia EPD.(7) City of Roswell WTP expansion includes additional yield from Big Creek, offline storage, and augmenting supply with groundwater.
0.167 0.167
309.2 309.2
Planned 2050 Withdrawal (MGD)
(1) Monthly average day is 1.2 times annual average day.
Sweetwater Creek
Cedar Creek Reservoirs
Crystalline Rock Aquifer
11.5
Big Creek 2.8
Total Withdrawal (MGD)
Chattahoochee River90.0
180.0
Source
Local Water
Provider
Current Permitted Withdrawal
Monthly Average (MGD)
Treatment Capacity (Note 5) 309.2
5.00
0.45
Crystalline Rock Aquifer 0.167
0.167
PAGE 22
JUNE 2017WATER RESOURCE MANAGEMENT PLAN
METROPOLITAN NORTH GEORGIA WATER PLANNING DISTRICT
Current Version
Fulton County - Water Draft Amendment15-Apr-20
Summary of Planned Sources
Monthly (Note 1) Peak Day
Atlanta/Fulton 105.0 140.0Atlanta 180.0 240.0Roswell 3.8 5.0
East Point 11.6 15.5Palmetto 0.45 0.6
College Park 0.1670 0.1670Roswell 0.1670 0.1670
301.2 401.4
Notes:
Summary of Needs
Scenario 1 Scenario 2 Scenario 1 Scenario 2248.5 266.2 298.2 363.9
-1.21 -1.21 -1.01 -1.01
247.3 265.0 297.2 362.9
Scenario 1
2025 (AAD-MGD)
Scenario 2
2025 (AAD-MGD)
Scenario 1
2050 (AAD-MGD)
Scenario 2
2050 (AAD-MGD)
Notes: 154.6 165.6 185.8 226.8
Phasing Plan
Atlanta-Fulton County WTP
Atlanta Hemphill WTP
Atlanta Chattahoochee WTP
Roswell Cecil Wood WTP (Note 7)
East Point WTP
Palmetto WTP
Roswell
College Park
Total Capacity (PD-MGD)
Notes:
Capital Projects
Non-Capital Programs
Source
Local Water
Provider
Current Permitted Withdrawal
Monthly Average (MGD)
Treatment Capacity (Note 5) 309.2
5.00
0.45
Crystalline Rock Aquifer 0.167
0.167
0.167 0.167
309.2 309.2
Planned 2050 Withdrawal (MGD)
(1) Monthly average day is 1.2 times annual average day.
Sweetwater Creek
Cedar Creek Reservoirs
Crystalline Rock Aquifer
11.5
Big Creek 2.8
Total Withdrawal (MGD)
Chattahoochee River90.0
180.0
401.4
The infrastructure to provide water to Fayette and Clayton Counties on a peak emergency basis should be maintained and expanded as necessary.
Evaluate required improvements to accommodate routine sale of 10 PDD-MGD to Coweta County.
The following non-capital programs are specific to Fulton County. These programs are in addition to those that apply to all counties within the Metro
Water District.
Maintain interconnections and water supply agreements with Clayton, Fayette, Coweta, DeKalb, Cobb, Forsyth, and Gwinnett Counties.
Future expansion should be concentrated at the Atlanta-Fulton County WTP because the intake is located at an upstream location and has an off-line
reservoir that improves its reliability.
The City of Atlanta should provide 10 PDD-MGD of water to Coweta County.
(6) The schedule shown above is intended to be a general guideline to identify general expansion needs. Expansion capacity may be required sooner or
later than indicated depending on local population and employment growth, water service extensions and other planning variables. Specific conditions
for withdrawal and operation permits will be determined by Georgia EPD.(7) City of Roswell WTP expansion includes additional yield from Big Creek, offline storage, and augmenting supply with groundwater.
0.167 0.167 0.167
64.9
5.0
15.5
0.6
3.0
13.9
0.6
3.0
13.9
0.6
240.0
Groundwater
0.167
(4) Demand and capacity are based on the combined total demand and capacity for Futon County as a whole. No attempt was made to analyze demand
by individual service provider within Fulton County or to consider existing service areas and previous bonding commitments associated with the
development of the existing infrastructure.
64.9
Chattahoochee Basin
90.0 90.0 140.0
136.5
Facilities (Note 6)
Existing (2016)Permitted Plant Capacity
(PD-MGD)
(5) Scenario 2 is being used for the phasing plan below.
Plant Capacity at End of Period
(PD-MGD)
Plant Capacity at End of Period
(PD-MGD)
By 2025 By 2050
136.5
401.4
(3) Peak day is 1.6 times annual average day.
To Coweta County 10.0
285.1
(2) The Bear Creek Reservoir is currently planned by the proposed South Fulton Municipal Regional Water and Sewer Authority, with an estimated yield
of 16.44 AAD-MGD. It would withdraw from the Chattahoochee River below Peachtree Creek. If constructed, it would supplement and offset water
supply needs for Fulton County.
Water Demands & Capacities
2025 Peak Day (Note 3)
(PD–MGD)
2050 Peak Day (Note 3)
(PD–MGD)
Fulton County Needs (Note 4)
Self Supplied
Total Projected Demand from Facilities (PD-MGD)
Total Projected Demand from Facilities (AAD-MGD)
PAGE 22
JUNE 2017WATER RESOURCE MANAGEMENT PLAN
METROPOLITAN NORTH GEORGIA WATER PLANNING DISTRICT
Coweta County - Wastewater
Summary of Needs
Capital Projects
Option for Senoia to decommission the current LAS and send flow to future facilities.Explore opportunities for beneficial effluent reuse with permits for wet weather discharge.
Basin Considerations
Phasing Plan Existing (2016)
Chattahoochee Basin
Coweta Arnco WPCP 0.1Coweta Arnall/Sargent WPCP 0.06Coweta Decentralized SystemsCoweta Bridgeport WPCPCoweta 12 Parks WPCPGrantville Colley Street LAS (Note 6) 0.15Grantville Ponds (Notes 5, 6) 0.13Grantville Yellow Jacket Creek WPCP (Notes 5, 6)Grantville New River WPCP (Notes 5, 6)Newnan Mineral Springs WPCP 0.75Newnan Wahoo Creek WPCP 3
Senoia LAS (Note 6) 0.49Sharpsburg WPCP (Notes 4, 6)Senoia Southeast WPCP (Note 6)Coweta Shenandoah WPCP 2
Sewered Needs (Note 7)
Notes:
7) The higher of Scenario 1 and Scenario 2 sewered flow forecasts is depicted.
Non-Capital Programs
Develop options for large industrial sites to be served by the County in the future.
5) Benefits of decommissioning these facilities will be investigated in the 2016 to 2025 time period.6) Proposed capacity is to be shared between these facilities as determined by joint local wastewater master planning.
The following non-capital programs are specific to Coweta County. These programs are in addition to those that apply to all counties within the Metro Water District. Undertake a joint planning study comprised of the county and local cities to develop a comprehensive, strategic plan for managing wastewater. The study should determine how to best utilize existing and proposed city and county treatment facilities to serve the whole area.
Develop multi-jurisdiction agreements among the county and cities, as needed. Develop multi-jurisdictional agreements between the county, City of Senoia, Fayette County and Peachtree City, as needed, for regional plan.
4) Sharpsburg WPCP is expected to have an initial capacity of 0.3 MGD by 2025. 0.15 MGD will be to LAS; an additional 0.15 MGD will either be to the LAS or new point source discharge.
Flint Basin
3.3 7.5
4 6
Total Capacity (MMF-MGD) 6.7 18.3 31.9
9.2 13.5
1) The schedule shown is intended to be a general guideline to identify general capacity needs. While the expansion capacities are intended to be in operation before the end of the period shown, exact timing of expansions should be determined by local wastewater master plans.
2) Max Month Flow (MMF) is 1.25 times the Average Annual Daily Flow (AAD).
3) When applying to Georgia EPD for wasteload allocations or wastewater discharge permits, individual jurisdictions are responsible for documenting that the request is consistent with this plan and that the plant capacities specified above are not exceeded.
3.76 7.6
0.78 0.78
6.5 10
Coweta Shenandoah WPCP, Senoia LAS and the proposed Sharpsburg and Senoia WPCPs are located in the Flint Basin. All other Coweta facilities are located in the Chattahoochee Basin.
Facilities (Notes 1, 2, 3)
By 2025 By 2050
Permitted Plant Capacity (MMF-MGD)
Plant Capacity at End of Period (MMF-MGD)
Plant Capacity at End of Period (MMF-MGD)
Additional capacity will be provided by expanding the existing Coweta County and Newnan facilities and by the construction of new Coweta County, Grantville, Senoia, and Sharpsburg facilities. If opportunities become available, the following options may be exercised:
Coweta County Sewered Needs 9.2 8.4 13.5 13.4Total Projected Sewered Flow to Plants 9.2 8.4 13.5 13.4Septic Flows (AAD-MGD) 5.0 4.7 6.5 6.4
Wastewater Flows & Capacities
2025 Maximum MonthAverage Daily Flow
(MMF–MGD)
2050 Maximum MonthAverage Daily Flow
(MMF–MGD)Scenario 1 Scenario 2 Scenario 1 Scenario 2
Current Version
Coweta County - Wastewater Draft Amendment
Summary of Needs
Capital Projects
Option for Senoia to decommission the current LAS and send flow to future facilities.
Explore opportunities for beneficial effluent reuse with permits for wet weather discharge.
Basin Considerations
Phasing Plan
Existing (2016)
Chattahoochee Basin
Coweta Arnco WPCP 0.1
Coweta Arnall/Sargent WPCP 0.06
Coweta Decentralized Systems
Coweta Bridgeport WPCP
Coweta 12 Parks WPCP
Grantville Colley Street LAS (Note 6) 0.15
Grantville Ponds (Notes 5, 6) 0.12
Grantville Yellow Jacket Creek WPCP
(Notes 5, 6)
Grantville New River WPCP (Notes 5, 6)
Newnan Mineral Springs WPCP 0.75
Newnan Wahoo Creek WPCP 3
Senoia LAS (Note 6) 0.49
Sharpsburg WPCP (Notes 4, 6)
Senoia Southeast WPCP (Note 6)
Coweta Crossroads LAS 0.23
Coweta Shenandoah WPCP 2
Coweta 12 Parks WPCP
Sewered Needs (Note 7)
Notes:
7) The higher of Scenario 1 and Scenario 2 sewered flow forecasts is depicted.
Non-Capital Programs
15-Apr-20
4 6
Ÿ Develop options for large industrial sites to be served by the County in the future.
5) Benefits of decommissioning these facilities will be investigated in the 2016 to 2025 time period.
6) Proposed capacity is to be shared between these facilities as determined by joint local wastewater master planning.
The following non-capital programs are specific to Coweta County. These programs are in addition to those that apply to all counties within the Metro Water District.
Ÿ Undertake a joint planning study comprised of the county and local cities to develop a comprehensive, strategic plan for managing wastewater. The study should determine
how to best utilize existing and proposed city and county treatment facilities to serve the whole area.
Ÿ Develop multi-jurisdiction agreements among the county and cities, as needed.
Ÿ Develop multi-jurisdictional agreements between the county, City of Senoia, Fayette County and Peachtree City, as needed, for regional plan.
4) Sharpsburg WPCP is expected to have an initial capacity of 0.3 MGD by 2025. 0.15 MGD will be to LAS; an additional 0.15 MGD will either be to the LAS or new point source
discharge.
Flint Basin
3.3 7.5
Total Capacity (MMF-MGD)
1) The schedule shown is intended to be a general guideline to identify general capacity needs. While the expansion capacities are intended to be in operation before the end
of the period shown, exact timing of expansions should be determined by local wastewater master plans.
2) Maximum Month Average Daily Flow (MMF) is 1.25 times the Average Annual Daily Flow (AAD).
3) When applying to Georgia EPD for wasteload allocations or wastewater discharge permits, individual jurisdictions are responsible for documenting that the request is
consistent with this plan and that the plant capacities specified above are not exceeded unless such exceedance has been approved through the Metro Water District's plan
amendment.
3.76 7.6
0.78 0.78
6.5 10
6.9 18.3 31.9
9.2 13.5
Coweta Shenandoah WPCP, Senoia LAS and the proposed Sharpsburg and Senoia WPCPs are located in the Flint Basin. All other Coweta facilities are located in the
Chattahoochee Basin.
Facilities (Notes 1, 2, 3)
By 2025 By 2050
Permitted Plant Capacity
(MMF-MGD)
Plant Capacity at End of Period
(MMF-MGD)
Plant Capacity at End of Period
(MMF-MGD)
Wastewater Flows & Capacities
2025 Maximum Month
Average Daily Flow
(MMF–MGD)
2050 Maximum Month
Average Daily Flow
(MMF–MGD)
Scenario 1 Scenario 2 Scenario 1 Scenario 2
Additional capacity will be provided by expanding the existing Coweta County and Newnan facilities and by the construction of new Coweta County, Grantville, Senoia, and
Sharpsburg facilities. If opportunities become available, the following options may be exercised:
Coweta County Sewered Needs 9.2 8.4 13.5 13.4
Total Projected Sewered Flow to Plants 9.2 8.4 13.5 13.4
Septic Flows (AAD-MGD) 5.0 4.7 6.5 6.4
WATER RESOURCE MANAGEMENT PLANMETROPOLITAN NORTH GEORGIA WATER PLANNING DISTRICT
PAGE 13
JUNE 2017
Coweta County Water Authority – WRM Amendment Request
April 9, 2020 - Amendment Request Letter from Integrated Science & Engineering on
behalf of Coweta County Water & Sewerage Authority
Atlanta / Savannah / Mobile
1039 Sullivan Road, Suite 200, Newnan, Georgia 30265 (p) 678.552.2106 (f) 678.552.2107
www.intse.com
April 9, 2020 Katherine Zitsch Director Metropolitan North Georgia Water Planning District 229 Peachtree Street Atlanta, GA 30303 Re: Coweta County Long Term Water Supply - MNGWPD Plan Amendment Request Dear Ms. Zitsch: Integrated Science and Engineering (ISE) respectfully submits this letter on behalf of Coweta County Water and Sewerage Authority (Authority) to formally request an amendment to the Metropolitan North Georgia Water Planning District Water Resource Management Plan (District Plan) adopted in June 2017. Background and Summary The Authority is requesting an amendment to the 2017 District Plan and its Appendices to indicate a 2050 planned monthly and peak day withdrawal from the Chattahoochee River of 21.3 Million Gallons per Day (MGD). The withdrawal is currently shown in Appendix B at 10 MGD peak day and 7.5 MGD monthly for the year 2050 for Coweta County. The amount currently shown is in addition to other sources that will be discontinued over the next 20 years as part of this amendment request. A 50 year planning effort is underway by the Authority and among the objectives are 1) for the Authority to provide for Coweta County’s own water supply needs and 2) to achieve resiliency in drought conditions from its supply sources. As a supplement to its own sources, the Authority currently purchases finished water from Newnan Utilities and the City of Griffin. These two sources, amounting to a maximum of 11.5 MGD by 2022 will become emergency interconnections only by 2039. Additionally, a permitted withdrawal of 4.9 MGD from a small tributary of the Chattahoochee River named Cedar Creek, has proven over the years to be unreliable in drought conditions and will be discontinued in favor of the proposed main stem withdrawal from the Chattahoochee River. The 50-year planning effort by the Authority indicates an anticipated withdrawal of 47.4 MGD by the year 2070. We estimate that the proposed main stem withdrawal from the Chattahoochee River will be implemented in approximately 3 to 4 phases over 50 years. The phasing plan will be refined and finalized as additional planning and engineering efforts are completed. As shown herein, the proposed Chattahoochee River withdrawal will allow the Authority to independently and reliably
April 9, 2020 Katherine Zitsch Page 2
serve the citizens of Coweta County for many years to come. Presented below is supporting data and computations for the proposed withdrawal including population projections, per capita water usage rate forecasts, an economic development buffer, and a safe yield analysis. Demand Projections To develop a 50-year projected demand, we chose to use a base per capita usage rate developed by the Atlanta Regional Commission (ARC) shown in Table 4-1 of the District Plan. We also selected ARC population projection data from the District Plan for demand computations as it is the most conservative of the sources considered. The population data was compared to 2012-2057 Governor’s Office of Planning and Budget (OPB) projections used in the District Plan, 2018-2063 OPB projections, 2015 ARC projections, and draft 2019 ARC projections. Again, while the ARC population projections from the District Plan result in conservative demand projections, potentially higher than what may actually be experienced, reliance on this demand projection provides greater drought resiliency for the Authority. The conservative demand projection will also provide some leeway for non-revenue water. Non-revenue water rates are shown in American Water Works Association (AWWA) Water Loss Audits from 2016, 2017 and 2018 at 4.2%, 9.2%, and 7.1%, respectively. ISE used four parameters to develop the projected demand: existing homes, future homes, an economic development buffer, and a peaking factor. The demand is further segregated by residential and non-residential sectors so as to highlight trends unique to each sector. The following equation was used to project future water demands. The peaking factor is not applied to the economic development buffer; industrial demands are expected to remain steady throughout seasonal changes, and are therefore not peaked. Projected Future Water Demand = [Residential Demand + Non-Residential Demand] × 𝑃𝑃𝑒𝑒𝑎𝑎𝑘𝑘𝑖𝑖𝑛𝑛𝑔𝑔 𝐹𝐹𝑎𝑎𝑐𝑐𝑡𝑡𝑜𝑜𝑟𝑟 + 𝐸𝐸𝑐𝑐𝑜𝑜𝑛𝑛𝑜𝑜𝑚𝑚𝑖𝑖𝑐𝑐 𝐷𝐷𝑒𝑒𝑣𝑣𝑙𝑙𝑜𝑜𝑝𝑝𝑚𝑚𝑒𝑒𝑛𝑛𝑡𝑡 𝐵𝐵𝑢𝑢𝑓𝑓𝑓𝑓𝑒𝑒𝑟𝑟
where
Residential Demand = (Existing Homes @ 57 gpcd) + (Future Homes @ 36 gpcd)
and
Non-Residential Demand = (Existing Population @ 38 gpcd) + (Additional Future Population @ 24 gpcd) Note: gpcd is gallons per capita per day Table 4-4 of the current MNGWPD Plan was used to determine the total per capita use rate, inclusive of residential and non-residential demand, of 95 gpcd. In order to project demand for
April 9, 2020 Katherine Zitsch Page 3
residential and non-residential users, past billing records were used to determine the consumption of each sector. It was found that residential consumption accounted for approximately 60% of all water used over the course of a year, while non-residential consumption accounted for approximately 40%. The per capita rate determined from the billing records favorably compares with the rate shown in Table 4-4. Applying the 60/40 ratio to the 95 gpcd total use rate produced an existing residential use rate of 57 gpcd and an existing non-residential use rate of 38 gpcd. In order to estimate future use rates, accounting for improved efficiencies and more stringent plumbing codes, the Residential End Uses of Water, Version 2 Executive Report published by the Water Research Foundation was reviewed and selected for establishing a baseline future residential rate. The report substantiates data suggesting an 18.2% reduction in residential consumption within the coming years. Based on data shown in the report, it is anticipated that this reduction can be expected in the next 20 to 25 years. In order to account for improved efficiencies over the 50 year planning horizon, the reduction rate of 18.2% was doubled to a 36.4% reduction. This reduction was applied to the existing residential per capita rate, producing a future residential per capita rate of 36 gpcd. The 60/40 split of user class was applied, producing a future non-residential per capita rate of 24 gpcd. These rates combined produce a total future per capita rate of 60 gpcd. The number of existing homes was determined using 2010 Census data for Coweta County and the cities of Newnan and Senoia. Existing homes were assigned a per capita rate of 57 gpcd to reflect current residential use rates and dated plumbing codes and fixtures. A per capita rate of 38 gpcd was used for the existing population to reflect current non-residential use rates. Future homes, derived from the ARC population projections extended to the year 2070, were assigned a per capita rate of 36 gpcd to reflect modern plumbing codes and water conserving fixtures. A per capita rate of 24 gpcd is used for the future population to account for future non-residential demand. In order to project demand for the Authority’s service area only, the Carl Vinson Institute of Government at the University of Georgia (CVI) was commissioned to provide population projections for the cities of Newnan and Senoia, as these cities both have independent water supplies. The populations projected by CVI were subtracted from the ARC county level projections to net the population to be served by the Authority. The persons per household for Coweta County from the United States Census Bureau was then used to determine the number of homes from the given population. Please see the table below for residential per capita rates.
April 9, 2020 Katherine Zitsch Page 4
Table 1: Residential Per Capita Usage Rates
2010 (Existing) 2040 2050 2070 Coweta County Population1 127,317 235,587 256,038 321,499 Population of Newnan and Senoia2 36,346 70,733 79,564 100,273 Population Served by CCWSA 90,971 164,854 176,474 221,226 Number of Homes (2.72 Persons per Home)3 33,445 60,608 64,880 81,333 Residential Per Capita Rate (gpcd) 57 47.6 46.8 44.6 Total Residential Demand (MGD) 5.2 7.9 8.3 9.9
1Extended from ARC 2050 projections used in the 2017 District Plan 2From Carl Vinson Institute of Government at the University of Georgia 3Using persons per household, 2013-2017, from US Census Bureau for Coweta County
Table 2: Non-Residential Demands
2010 (Existing) 2040 2050 2070 Coweta County Population1 127,317 235,587 256,038 321,499 Population of Newnan and Senoia2 36,346 70,733 79,564 100,273 Population Served by CCWSA 90,971 164,854 176,474 221,226 Non-Residential Per Capita Rate (gpcd) 38 31.7 31.2 29.8 Total Non-Residential Demand (MGD) 3.5 5.2 5.5 6.6
Monthly demand factors were determined from three years’ past billing data from the Authority, between October 2016 and September 2019. These are presented in Table 2 for each month. As shown, the maximum monthly peaking factor is 1.17. This factor was applied to the projected residential and non-residential flows, resulting in a 2070 peak month demand of 19.3 MGD. A daily peaking factor was determined from past water system operating data. The daily peaking factor was determined to be 1.51, producing a 2070 peak day demand of 24.9 MGD.
April 9, 2020 Katherine Zitsch Page 5
Table 3: Monthly Demand Factors
Month Demand Factor January 0.85 February 0.98 March 0.84 April 0.88 May 0.97 June 1.14 July 1.10 August 1.08 September 1.17* October 1.10 November 1.05 December 0.86
The final parameter to determine the projected future water demand is the economic development buffer. An industrial water use rate of 1,500 gpd/acre was estimated based on several past requests at a large planned industrial development and a large existing industrial development within the County. A large planned industrial development named Bridgeport has attracted several potential industries that required ample water supply. The requests have ranged from 1,127 to 3,268 gpd/acre. The demand rate of a large existing industrial park within Coweta County was also determined using billing records. The rate was found to be 1,300 gpd/acre, accounting for greenspace, roadways, and other unused space within the industrial park. The Land Development Handbook, Second Edition, by the Dewberry Companies, recommends a design flow for industrial developments in the range of 600 gpd/acre to 10,000 gpd/acre. A design rate of 1,500 gpd/acre was selected as an acceptable average of the current industrial usage rates, requested rates, and cited rates. Using this rate applied to areas planned for industrial development in the Coweta County 2016-2036 Comprehensive Plan, in addition to known current industries which will increase their water demand, an Economic Development Buffer of 10.1 MGD was calculated, as shown below in Table 4.
Table 4: Economic Development Buffer Industry Acreage Flow (MGD) Planned Industrial Development Within County 4,600 6.9 Future Capacity of Existing Industries -- 3.2 Total Economic Development Buffer -- 10.1
April 9, 2020 Katherine Zitsch Page 6
The Economic Development Buffer of 10.1 MGD applies to the end of the 50 year planning horizon, 2070. In order to develop intermittent demand projections, the Economic Development Buffer was prorated from 0 MGD in the year 2020 to 10.1 MGD in the year 2070.
Table 5: Projected Flow Demands
Demand Type 2025 Demand
(MGD) 2040 Demand
(MGD) 2050 Demand
(MGD) 2070 Demand
(MGD) Residential Demand 6.5 7.9 8.3 9.9 Non-Residential Demand 4.4 5.2 5.5 6.6 Economic Development Buffer 1.0 4.0 6.0 10.1 Annual Average Demand 11.9 17.1 19.8 26.5 Monthly Average Demand 13.7 19.3 22.1 29.3 Peak Day Demand 17.5 23.8 26.9 34.9
Water Sources Three sources currently provide for the Authority’s supply needs: Newnan Utilities, City of Griffin, and the Authority’s own BT Brown Water Treatment Plant. Contractual agreements exist with minimum purchase requirements from Newnan Utilities and the City of Griffin. The Authority also has two existing emergency connections with the City of Atlanta water system. The table below summarizes the Authority’s contractual agreements.
Table 6: Contractual Agreements for Water Supply
Supplier Effective Date Minimum (MGD) Maximum (MGD)
Griffin Present - 2022 3 4.5 2022 – 20491 5 7.5
Newnan Utilities Present - 2021 2.4 4
2021 - 2022 1.8 4 2022 - 2029 1.25 4
1The Authority has an early exit option in the purchase contract of 2039. As Authority’s demand continues to increase over the years, the Authority’s ability to meet the growing demand through its own source will become imperative, as will the need to achieve resiliency in drought conditions. This will be accomplished in a phased manor as the external sources are phased in to emergency connections only. The supply infrastructure from Newnan Utilities and the City of Griffin are hydraulically limited, and these two jurisdictions must provide for their own growing needs over the coming years. An initial expansion to the B.T. Brown Water Treatment Plant is anticipated accordingly, and it is our opinion based on methodology described above and shown in Table 5, that the 2025 peak day demand will be 17.5 MGD. We recommend that the Phasing Plan shown in Appendix B be modified accordingly. By
April 9, 2020 Katherine Zitsch Page 7
the year 2050, additional expansions at the B.T. Brown Water Treatment Plant will be considered, as will other alternatives including a new water treatment plant and additional storage alternatives, and we are recommending that plant capacity(s) at 26.9 MGD be shown for the year 2050 in the Phasing Plan of Appendix B. Safe Yield The existing BT Brown Reservoir will be used for raw water storage for the proposed increase in supply from the Chattahoochee River. A safe yield analysis was performed by AECOM to determine the Chattahoochee River withdrawal rate needed to achieve a safe yield of 26.5 MGD from the BT Brown Reservoir. The safe yield in this case is defined as a water balance analysis that accounts for all inflows (precipitation over reservoir water surface, natural stream flows into the reservoir, pumped flows into the reservoir), and outflows (evaporation from reservoir water surface, required flow release below the dam/instream flow protection threshold (IFPT), and withdrawals). The safe yield analysis model developed by AECOM uses a water balance concept to calculate the change in storage on a daily basis. The change in storage at the end of the day is equal to inflows minus outflows. End of Day Storage = Beginning of Day Storage + Tributary Inflow + Precipitation + Pumping from Chattahoochee – Evaporation – IFPT Reservoir Release – Water Withdrawal*Monthly Demand Factor – Spill (if any) AECOM constructed a spreadsheet-based model to estimate the safe yield based on available historical daily streamflow that covers the recent records of drought (2007-2008), and to estimate the amount of pumping required from the Chattahoochee River on a daily basis to support the water supply safe yield. The analysis included the following parameters and assumptions:
• Daily simulation based on available historical hydrologic (streamflow) and meteorological data (precipitation and evaporation).
• IFPT below the proposed river intake based on Georgia Environmental Protection Division (EPD) reviewed and approved methodology incorporating the M7Q10 of the unimpaired flow for the Chattahoochee River from the Peachtree Creek confluence to the Whitesburg USGS gage location (data provided by EPD, October 2018) and the existing IFPT at Peachtree Creek.
• Seasonal demand fluctuations incorporated by including monthly demand factors in the safe yield model. The monthly factors were calculated based on water billing records provided by the Authority for the period of October 2016 to September 2019 (3 years). See Table 3 for monthly demand factors.
April 9, 2020 Katherine Zitsch Page 8
To support a projected annual average safe yield of 26.5 MGD from BT Brown Reservoir, the maximum daily pumping rate required from the Chattahoochee River in the year 2070 is 47.4 MGD. In order to support the water demands of Coweta County for the 50-year planning horizon, the Authority plans to apply for a withdrawal permit with the Georgia EPD for 47.4 MGD from the Chattahoochee River, as well as a new withdrawal permit from BT Brown Reservoir. The Authority requests that the District Plan be amended as shown in Table 7 to reflect this desire.
Table 7: Summary of Planned Sources
Water Supply Source
2017 District Plan Appendix B
- Planned 2050
Withdrawal (MGD)
District Plan Amendment Request
- Planned 2050
Withdrawal (MGD)
EPD Withdrawal Application
- Planned 2070
Withdrawal (MGD)
Monthly Peak Day Monthly Peak
Day Monthly Peak Day
Chattahoochee River 7.5 10 21.3 21.3 47.4 47.4
BT Brown Reservoir 7.5 10 22.1 26.9 29.3 34.9
Wastewater The Authority currently operates a centralized sewer system to collect and treat wastewater from a portion of its customer base. The largest treatment plant is currently permitted to discharge 2 MGD within the Flint River basin, while the other small treatment plants discharge within the Chattahoochee River basin (as shown in the current allocation of wastewater discharges in Appendix B). As the projected County population growth and resulting water demand increase occurs, so will the need for additional wastewater collection and treatment capacity. The Authority’s centralized sewer system will be expanded to accommodate the increased demand, returning a portion of the withdrawn water to surface waters within the County. Please let me know if you need further clarification or additional information to support this request, and please do not hesitate to contact the undersigned accordingly.
April 9, 2020 Katherine Zitsch Page 9
Kind regards, INTEGRATED SCIENCE & ENGINEERING, INC.
L.H. (Dan) Davis, Jr, PE Project Principal Engineer CC: Jay Boren, Coweta Water and Sewerage Authority Tai Yi Su, AECOM Bennett Weinstein, Step Forward Strategies, LLCAttachments: Coweta County Projected Industrial Development Map Coweta County Future Development Map
US Hwy 29US Hwy 27 (Alt)
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1 inch = 2.5 miles
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LegendMunicipalities
Floodplain
Projected Industrial Areas
CCWSA Service Area
* Total Area of Projected Industrial Growth = 4,600 Acres
Coweta County Projected Industrial Development Map
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GreentopCrossroads
WillisCrossroads
StewartCrossroads
Sargent
Arnco
Fischer'sCrossroads
RaymondCrossroads
EastNewnan
MadrasCrossroads
VineyardCrossroads
HunterCrossroads
Stephen'sCrossroads
HandyCrossroads
RoscoeCrossroads
CorinthCrossroads
WelcomeCrossroads
BlackjackCrossroads
PowersCrossroads
ThomasCrossroads
Lake McIntosh
Chattahoochee River
Newnan
Senoia
Grantville
Turin
Moreland
Palmetto
Sharpsburg
Haralson
GORDON RD
CORINT
H RD
SMOK
EY R
D
FISCHER RD
POPLAR RD
MINIX RD
MOOR
E RD
MT CAR
MEL RD
WELCOME RD
TOMMY LEE COOK RD
OLD CO
RINTH
RD
BOONE RD
HANDY RD
MARTIN MILL RD
DEAD OAK RD
ELDE
RS M
ILL RD
COWETA HEARD RD
TOPE
RD
LINE CREEK RD
SEWELL MILL RD
W GRANTVILLE RD
ALLE
N RD
REES
E RD
AL ROBERTS RD
OLD
HIGH
WAY 8
5
HAYNIE RD
BEAR CREEK RD
LUTH
ER BAILE
Y RD
HOLB
ROOK
RD
J D WALTON RD
BRIM
ER RD
LINCH RD
HERR
ING
RD
POSEY RD
WALTON RD
MCINTOSH TRL
BOHANNON RD
HINES RD
WITCHER RD
ROWE
RD
BEAVERS RD
ROCK HOUSE RD
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Future Development Map
Coweta County 2016-2036 Comprehensive Plan
8Employment Center -Commercial/OfficeEmployment Center -Industrial
Future Land Use
Commercial Corridor
Neighborhood Institutionaland Service Corridor
Runway Protection ZonePlanned Interchange
Planned Roadway
Crossroads Service Center
Interstate Gateway
Mill Village
Infill Neighborhood Medium Density
Transportation/Communication/Utilities
Rural Conservation
Lakeside Residential
Infill Neighborhood Low Density
Conservation
Lake/Pond
City Boundary
County Boundary
ChattahoocheeBend State Park
Cedar Creek ZoningDistrict Boundary
Brown's MillBattlefield
0 52.5Miles
River/Stream
Interstate
RampState Highway
County Road
Road
Transmission Easement
Coweta County Water Authority – WRM Amendment Request
Public Comment Period Notice
April 16, 2020 to May 16, 2020
Public Notice Order Confirmation
Ad Order # Ordered ByPO #0000467493 Debra Little
Account # AddressName
9006836 ATLANTA REGIONAL COMMISSION SUITE 100, 229 PEACHTREE CENTER NE, ATLANTA, GA 30303
Phone
404-463-3254404-463-3162
EmailFax
Amount Due
Placement: Government Notice Miscellaneous
Run Dates: 04/15 # of Ins: Ad Size:
Subject:
1
Position: County:
May 16, 2020
Daily Report
125 Words
25.00
Gross Amount
5.00 20.00
Affidavit Fee
Ad Text Corrections
Please review and provide corrections as needed.
Payment By Credit Card ( ) Visa ( ) MC ( ) Amex
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/
From: Danny JohnsonTo: Danny JohnsonSubject: Proposed Amendment to the Water Resource Management PlanDate: Thursday, April 16, 2020 9:15:57 AM
The Metro Water District has posted a proposed amendment to the Water Resource ManagementPlan as requested by the Coweta County Water and Sewerage Authority to the District’s website.Here is the language from the public notice. Comments are due on May 16, 2020. METROPOLITAN NORTH GEORGIA WATER PLANNING DISTRICT AMENDMENT TO THE WATERRESOURCE MANAGEMENT PLAN. The Metropolitan North Georgia Water Planning District (theDistrict) is seeking public review and comment on a proposed amendment to the Water ResourceManagement Plan. This notice does not constitute the proposed amendment. To view the proposedamendment in its entirety, visit https://northgeorgiawater.org/plans-manuals/ or by calling (470)378-1548. The Water Resource Management Plan can be found at the same address. The commentperiod closes May 16, 2020. After consideration of public comments, the District Board will considerwhether the amendment will be incorporated into the Water Resource Management Plan.Comments can be sent via letter or email to: Water Resource Management Plans, 229 PeachtreeStreet N.E., Atlanta, Georgia 30303; EMAIL comments@northgeorgiawater.com. Daniel E. Johnson, PE | Manager | Metropolitan North Georgia Water Planning District |www.northgeorgiawater.org | 229 Peachtree Street NE, Suite 100, International Tower, Atlanta, GA30303 | O: 470-378-1552 | M: 404.683.2003 | djohnson@atlantaregional.org
Coweta County Water Authority – WRM Amendment Request
August 13, 2020 – Response to Public Comments Letter from Integrated Science &
Engineering on behalf of Coweta County Water & Sewerage Authority
Atlanta / Savannah / Mobile
1039 Sullivan Road, Suite 200, Newnan, Georgia 30265 (p) 678.552.2106 (f) 678.552.2107
www.intse.com
August 13, 2020 Ms. Katherine Zitsch Director Metropolitan North Georgia Water Planning District 229 Peachtree Street Atlanta, GA 30303 Re: MNGWPD Plan Amendment Request Comment Response Dear Ms. Zitsch: Following the application for a Metro North Georgia Water Planning District Plan Amendment by Coweta County Water and Sewerage Authority (Authority), the District received public comments from four stakeholders. Integrated Science and Engineering, on behalf of the Authority, appreciates the input received and after careful consideration respectfully offers the responses detailed below. Comments were received from the Chattahoochee River Keeper, the Middle Chattahoochee Regional Water Council, the State of Alabama, and the City of Atlanta. The comments are listed below, followed by our responses and thoughts in bold text. Chattahoochee River Keeper
1. The amendment request does not clearly indicate where wastewater will be returned. The plan to return wastewater to the Chattahoochee River basin is not reflected in Appendix B of the Plan or described in the amendment request. Additional detail on the final destination of water withdrawn from the Chattahoochee River is needed before the District can approve this amendment request. We refer to the outline of wastewater flows within the County in Appendix B. The Authority’s discharges into the Chattahoochee basin, by planned plant capacity, are scheduled to increase from 0.16 MGD to 7.6 MGD by 2050, and into the Flint Basin by planned plant capacity, from 2.23 MGD to 6 MGD by 2050. By scheduled plant capacity, approximately 56% of returned flows will be to the Chattahoochee basin, while 44% will be to the Flint basin. The computation by scheduled plant capacity does not however, accurately portray future return flows. To forecast wastewater needs for the Authority, water demand projections are segregated below into user types to project wastewater return rates. The following summarizes the assumptions for wastewater flow projections:
August 13, 2020 Ms. Katherine Zitsch Page 2
Residential: The County’s current ordinances and land use plan do not allow the Authority to serve residential sewer to new developments (with some exceptions), and the Authority is not aware of any future changes in this policy at this time. Therefore, the residential wastewater flow (sewered need) is assumed to remain at the current level through the planning horizon. Non-Residential and Industrial: It is assumed that 100% of the Authority’s industrial and non-residential customers will be connected to the sewer system by 2050. The non-residential and industrial wastewater flows are assumed to have a return rate of 73% (27% outdoor water use, Table 4-4, 2017 District Water Resource Management Plan). This is typical for existing non-residential and industrial users. Inflow and Infiltration: An additional 20% is applied to account for inflow and infiltration. The table below summarizes the projected wastewater flows for the sewer system and the anticipated future return rates. The wastewater return in the Authority’s service area is projected to increase from 16% in 2020 to 52% in 2050 based on existing residential sewer service ordinances. Should the County amend their policy for residential sewer service in the future, the return flow may further increase. CCWSA Return Flows (AAD-MGD) Developed Using Table 5 of the MNGWPD Plan Amendment Request Letter
Return Flow Type Current1 2025 2040 2050 2070 Residential2 0.22 0.22 0.22 0.22 0.22
Non-Residential 0.38 1.09 3.82 4.02 4.81 Economic Development
(Industrial) 0.71 0.73 2.93 4.40 7.34
Infiltration and Inflow NA3 0.36 1.35 1.68 2.43 Total Wastewater Return 1.31 2.41 8.33 10.33 14.79
AAD Water Demand 8.12 11.89 17.10 19.80 26.51 Percent Wastewater
Return 16% 20% 49% 52% 56%
Notes: 1. Based on current billing records and wastewater plant influent flows 2. Based on current residential sewer ordinances and land use plan 3. I&I for current flows are included in the residential, non-residential and industrial flows
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2. The population dynamics used to justify a short-range need for a 21.3 MGD withdrawal and long-range needs for a 47.4 MGD withdrawal are circumspect. Given the current COVID-19 conditions and their unknown effects on water supply operations and planning, it is highly probable that the region’s current public health and economic conditions will further reduce future population growth. What is the real purpose and need for this withdrawal? We agree that COVID-19 impacts on water supply operations in the region are unknown at this point. Metrics for the Authority are pointing to little to no impact from the pandemic at this time. The average daily demand for the last few months is at 9.56 MGD versus 9.47 MGD for the same period last year. Another metric is water meter sales over the last few months versus the same time frame last year which have increased. Finally, Georgia 811 Utility Protection Center locates requested of the Authority were the highest on record in April, and second highest in June. It is our opinion that it would be unwise to modify a 50 year plan given the limited impact the Authority is seeing at this time, and based on population projections performed by the ARC over the years that closely align with historic growth in Coweta County.
3. The future demand projection for 60 gallons per capita per day in 50 years is an aspirational and laudable goal. However, the calculation used to reach this data point—based upon the Water Research Foundation’s report titled Residential End Users of Water, Version 2 Executive Report—makes two critical assumptions. [Letter, p. 3] First, that improved efficiencies will reduce demand. And second, that “more stringent plumbing codes” will be implemented in Georgia. Additionally, outdoor water use is significant component of residential use. How did the applicant calculate for outdoor water use and peak demands to reach future demand projections? With these considerations in mind, the CCWSA service area’s demand projection may be significantly under-estimated in this amendment request. Our past experience with utility systems is consistent with findings in the WRF’s report and with what is being observed in the Metropolitan North Georgia Water Planning District. Improved efficiencies and plumbing code updates have reduced total per capita water demand over the last 20 years, and industry consensus is that this trend will continue in the years to come. A publication by the EPA in 2016 titled “Best Practices to Consider When Evaluating Water Conservation and Efficiency as an Alternative for Water Supply Expansion” highlights several studies that support declining per capita use rates, both for new homes and for existing ones. The 60 gallon per capita per day projection rate we reference from Water Research Foundation’s report includes outdoor water use, constituting approximately 20% of the rate (consistent with MNGWPD methodology), and anticipates continued
August 13, 2020 Ms. Katherine Zitsch Page 4
efficiency improvements in the future. A daily peaking factor of 1.51 was applied to the residential and non-residential demands to reach a future peak demand; a peaking factor was not applied to the economic development buffer since industrial demand does not fluctuate with daily or seasonal climate changes in our experience.
4. Early discussion between CRK and the applicant indicated a diversion structure may be constructed across the Chattahoochee River to direct water into the proposed raw water intake depending upon the selected location. The proposed diversion dam could stymie the Riverlands’ plans, limit overall recreational options and use of this river section, and would introduce yet another navigational hazard to the Chattahoochee River. Planning for the location and configuration of the intake structure is going to necessitate significant ecological studies, hydraulic modeling, surveying, and geotechnical engineering. These functions are performed as part of permitting with the Georgia EPD and the Army Corps of Engineers. The Authority is planning to avoid a diversion structure if engineering evaluations so conclude. Preliminarily, the Authority is considering a structure similar to the one shown in the link which is situated in the river bank and has little impact on the lateral river bed: https://www.wwdmag.com/eastvale-water-treatment-plant-new-raw-water-intake-project
5. According to Georgia’s Draft 2020 305(b)/303(d) Integrated Report (Water Quality in Georgia Report), the 21 miles of river where CCWSA’s withdrawal may be located are not meeting their water quality designation. The Pea Creek to Snake Creek, and Snake Creek to Wahoo Creek are designated for “fishing” and are impaired due to fecal coliform. What actions will be employed to improve the river’s water quality so the sections can be upgraded to a “drinking water” use to support a municipal water withdrawal? The Authority conducted preliminary water quality sampling and analysis between March 2017 and May 2018 at and near the proposed intake location from the Chattahoochee River. The need to upgrade the proposed water treatment plant will be evaluated by CCWSA based on the water quality obtained at the proposed intake location. The rules for Minimum Criteria for Large Water Supply Watersheds (Georgia DNR, Environmental Protection Division, Chapter 391-3-16 Rules for Environmental Planning Criteria 391-3-16-.01 Criteria for Water Supply Watersheds) states that “The stream corridors of a large water supply watershed tributary to the water supply intake shall have no specified minimum criteria for protection”. CCWSA will also work with the EPD for the evaluation of the section of the river should the proposed withdrawal is approved. In addition, CCWSA is
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committed to educational outreach to improve awareness of non-point source reduction within its service area.
Middle Chattahoochee Regional Water Council
1. The projections for wastewater treatment by septic tanks across the planning period appears quite low relative to the experience of neighboring counties, some of which are a part of our water planning region. What is the basis for this projection? One of the high priority management practices in the Middle Chattahoochee Regional Water Plan is focuses on the importance of wastewater returns. The District developed projections for wastewater treatment for septic tanks using the number of existing septic tanks from department of public health records and population projections. We chose not to change the projections for wastewater treatment by septic tanks as we are not changing the residential water demands.
2. The Council is concerned about the return of water to the Chattahoochee River and the larger ACF System to support downstream water uses and flows. We encourage the Metro Water District Board to address the need for wastewater infrastructure planning as well as water infrastructure planning in Coweta County as it considers this amendment. Achieving high return rates is a key to sustainability, particularly when the resource is stressed. In areas of more intense development, we recommend that the County require centralized wastewater treatment for new development. Please reference our response to comment 1 from the Chattahoochee River Keeper.
3. The projected future per capita water use rate of 60 gpcd seems quite low. It assumes a
linear extrapolation of a projected decline of 18.4% over 20 to 25 years to a 50-year period. However, additional reductions are likely to become more difficult to attain over time. Is a linear assumption valid? If the future water use rates are higher than projected, what will the impacts be to the Chattahoochee river withdrawal by the Coweta County Water and Sewerage Authority? Please reference our response to comment 3 from the Chattahoochee River Keeper.
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State of Alabama
1. The CCWSA’s proposal – which seeks to pump water directly out of the Chattahoochee River into BT Brown Reservoir and then discharge some of that treated wastewater back into the Flint River Basin – will harm Alabama, as well Georgia. As you know, the Alabama/Georgia border south of West Point is delineated by the Chattahoochee River. Many state-line cities, businesses and individuals rely on a dependable flow of water coming down the river. The proposed interbasin transfer here will negatively impact these local communities in a number of ways. For example, reduced downstream flows will result in fewer releases being made for hydropower generation at the various dams on the river, ultimately leading to higher electricity costs. Likewise, reduced flow will impair water quality. Not only will that hurt the river’s ecosystems and limit recreational opportunities, but it will make it more difficult for businesses with pollutant discharge permits to comply with those permits and attendant state water quality standards. These are just some of the adverse downstream effects – there are more – that would result if the CCWSA’s proposal is approved. 1) CCWSA is planning on expanding wastewater treatment capacity in both Flint
and Chattahoochee River Basins (District Plan Appendix B). The wastewater return to both basins from the County is projected to increase over the years.
2) The impact of the proposed withdrawal to the Chattahoochee River flow is minimal, as demonstrated by the two figures on the following page. Figure 1 shows that the proposed withdrawal is a fraction of the Chattahoochee River flow during the 2007-2008 drought. Figure 2 shows that the difference in streamflow with and without the proposed withdrawal is not discernible during the 2007-2008 droughts (see details in AECOM memorandum) and this difference will be even smaller during average flow conditions. The withdrawal will only be made to allow the instream flow protection threshold (IFPT) to pass below the proposed intake. The IFPT will be set to protect water quality, aquatic life, and the need of downstream users.
August 13, 2020 Ms. Katherine Zitsch Page 7
Figure 2 The difference between pre-pumping (without proposed withdrawal) and post-pumping (with proposed withdrawal) flows in the Chattahoochee River at the proposed intake location or downstream are not discernible.
2. The proposed interbasin transfer undermines the decision-making process that led the
U.S. Army Corps of Engineers to adopting new operations for the ACF River Basin in 2017. One important decision the Corps reached as part of that process was to allocate
Figure 1 The proposed withdrawal is a fraction of the Chattahoochee River flow at the proposed intake location during the2007-2008 drought period and an even smaller fraction during normal average flow conditions.
August 13, 2020 Ms. Katherine Zitsch Page 8
additional storage space in Lake Lanier (which is part of the Chattahoochee River Basin) for water supply to ensure that metro Atlanta’s demands could be met. That decision was premised in part upon the Corps’ assessment that, notwithstanding that allocation, sufficient water would still flow downstream such that the impact on hydropower, the environment and other criteria would be minimal. The CCWSA’s proposal, if adopted, would call that assessment into question. Had the Corps accounted for the interbasin transfer, its determination very well may have been different, and the allocation may never have been approved. Thus, in the event that the District approves CCWSA’s proposal, the Corps’ allocation of storage space at Lake Lanier will need to be revisited. More specifically, the storage space allocated to Georgia’s direct withdrawals from Lake Lanier will need to be diminished by an amount that offsets the CCWSA’s withdrawal from the Chattahoochee and interbasin transfer into the Flint. See the attached memorandum by AECOM – 1) An estimate of the wastewater returns to both the Chattahoochee and Flint
Basins are illustrated. CCWSA is planning on expanding wastewater treatment capacity in both Flint and Chattahoochee River Basins (District Plan Appendix B). The wastewater return to both basins from the County is projected to increase over the years. Please refer to the response to Comment 1 from the Chattahoochee River Keeper for wastewater return estimates.
2) The Corps operates five Federal reservoirs in the ACF Basin as a system, so the
return to Flint River will contribute to the inflows to Lake Seminole (or Jim Woodruff Reservoir). This quantity is not, “lost flow,” and will contribute to the consideration used by the Corps when balancing the operation of the ACF Basin.
3) The demand growth of CCWSA is within the range of long-term planning for
the District. The CCWSA evaluated its water supply alternatives extensively before selecting the preferred alternative that meets its projected demand. The increase in total county surface water withdrawal would need to be supported by water supply sources within the Chattahoochee or Flint River Basins, whether Coweta develops additional dependable supply or obtains additional need from the entities it currently has agreements with (City of Atlanta and Newnan-Chattahoochee Basin and Griffin-Flint Basin). The proposed withdrawal will reduce Coweta’s dependence on the other water supply sources.
3. In addition to revisiting the allocation at Lake Lanier, the Corps will need to reconsider
whether it has to make additional releases from Lanier and West Point Lakes to ensure that minimum flows are met downstream. Under the Corps’ current operations, minimum flows must be maintained below Jim Woodruff Reservoir (as measured at the gage near Blountstown, FL). Any additional water removed from the Chattahoochee River during a
August 13, 2020 Ms. Katherine Zitsch Page 9
drought of record would require additional releases, which may be drawn from either Lanier or West Point or a combination of the two. See details in AECOM memorandum – The Corps operates five Federal reservoirs in the ACF Basin as a system, and releases made to maintain the minimum flow below Jim Woodruff Dam reflect the downstream end-results for system wide operations. The current operating rules target a minimum flow of 5,000 cfs as measured at Blountstown, FL, except when the system is in the Drought Zone. The minimum flow target is based on the composite conservation storage of all three major storage projects (Lake Lanier, West Point Lake and Walter F. George Lake) and the total basin inflow. The impact of the proposed CCWSA withdrawal to the ACF Basin operation is minimal during drought or non-drought times and the proposed withdrawal is unlikely to trigger a change in the ACF Basin operation during a drought similar to the magnitude of 2007-2008 drought.
City of Atlanta
1. Approval of a new water withdrawal for CCWSA will mean withdrawing raw water downstream of, and relatively close to, the existing effluent discharge locations for all the City’s effluent discharge locations. Siting a drinking water withdrawal within a relatively close stream travel time to these major effluent discharge locations reduces the mixing time within the Chattahoochee River available to assimilate and diffuse remaining pollutants within the discharges. In effect, such siting may be considered to create a potential situation of defacto, non-engineered potable reuse where the effluent discharged from the City’s wastewater treatment plants is used for drinking water purposes after withdrawal from the Chattahoochee. The Authority conducted preliminary water quality sampling and analysis between March 2017 and May 2018. Constituents analyzed included iron, manganese, e. coli, turbidity, fecal coliform bacteria, total organic carbon, total suspended solids, alkalinity, conductivity, and pH. Samples were taken in periods between rainfalls events (average flow conditions), at the commencement of rain events, and in intervals after the commencement of rainfall at 24, 48, 72, 96 and 120 hours. These testing intervals were planned to anticipate travel time from point and non-point sources from urbanized sources upstream including Atlanta. The preliminary results from the testing are similar to findings in a Treatability Analysis performed for the South Fulton Municipal Regional Water and Sewer Authority further upstream. Our preliminary testing was performed solely for the Authority’s planning purposes, and a detailed Treatability Analysis will be performed by the Authority as part of future permitting with the Georgia EPD.
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2. Siting a drinking water intake in proximity to such significant upstream pollutant discharges will require a detailed source water assessment to evaluate the suitability of a downstream Chattahoochee River to serve as a raw water intake location. Such a study should include a temporal assessment of microbiological, physical, and chemical parameters. Allowing an amendment of the Water Resource Management Plan is believed to be premature until such technical studies can be completed to demonstrate such suitability. The City believes that CCWSA should be required to perform the analytical analysis, including water quality dispersion modeling of the discharges from Atlanta’s WRCs to determine any impact to raw water quality at the proposed intake from the Chattahoochee River as proposed by CCWSA. Such analysis must demonstrate that CCWSA’s proposed withdrawal will not require Atlanta to upgrade the City’s WRCs. If there are water quality concerns that arise from the modeling or other assessments, CCWSA should provide a study on the water treatment processes required to provide safe, reliable drinking water. See response to comment number 1 to the City of Atlanta, furthermore, the COA notes below in comment #5 their own plans for a future withdrawal downstream of their own non-point and point discharges. Given the substantive distance of Coweta County’s withdraw downstream of the city limits of Atlanta (greater than 18.5 direct miles) and preliminary water quality sampling, we believe that operational strategies and advanced water treatment (if required) will result in quality drinking water for the citizens of Coweta County. A Source Water Assessment and a Treatability Analysis are efforts that are performed as part of permitting with the Georgia EPD.
3. The City is also concerned with potential future budgetary and technical operational
impacts on the WRCs, WQCFs, and CSCFs. Siting a raw water intake downstream of these effluent discharge locations may be expected to result in more stringent effluent discharge limitations thus creating significant additional technological and budgetary challenges for the City to upgrade its treatment facilities. Even now, it has become increasingly difficult for the City to meet the ever more stringent effluent limitations. Further, during emergency situations caused by more extreme weather conditions that are expected due to adverse climate change impacts, the facilities may not be capable of meeting either current or the more stringent discharge limitations. Thus, CCWSA may be at risk of shutdown of the new water withdrawal during such potential emergency conditions. As stated in our response to the City of Atlanta’s comment 2 above, the Authority will implement operational strategies and if necessary, advanced water treatment, to ensure quality drinking water for Coweta County citizens.
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4. In addition to anticipated more stringent effluent limitations at the City’s treatment facilities, other property owners adjacent to the Chattahoochee River upstream of the new water withdrawal location will be affected. The watersheds adjacent to the new withdrawal location will become water supply watersheds and thus will become subject to more stringent nonpoint source controls required to protect such withdrawal locations from pollutant loads. The Authority’s northern-most withdrawal location under consideration is much greater than 7 miles downstream of the Atlanta City limits, therefore not triggering these non-point source controls.
5. Atlanta has in good faith planned short-term, intermediate, and long-term Capital
Improvement Program (CIP) projects to provide adequate, quality drinking water services to its entire service area. Relative to the south Fulton service area that includes the two connections to the CCWSA system, the City has in excess of $200 million of near-term CIP projects detailed in the 2020 Water Master Plan that are designed to serve projected growth in the area. It is noteworthy that one of these major CIP activities is an option to develop a new water treatment facility to further ensure adequate service and system resiliency for the south Fulton area. The facility would transport water from the current Chattahoochee River withdrawal to the proposed new facility. Due to the distances involved, the City is also considering a raw water intake further downstream. While this is currently considered a secondary option, the City is considering initiating the planning necessary to determine the feasibility of installing another Chattahoochee River withdrawal. The cost assessment will also consider the projected impacts on the City’s wastewater facilities. The difference in a proposed Atlanta raw water withdrawal from a CCWSA water withdrawal is that Atlanta would be able to offset the additional costs of wastewater improvements with additional revenue from the water and sewer charges. The Authority seeks to develop a fully independent and resilient water system for the citizens of Coweta County, interconnected with neighboring communities for mutual instances of service disruptions caused by emergencies.
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The Authority appreciates the opportunity to provide these responses, and concludes by saying that it shares the vision expressed by the Chair of the Middle Chattahoochee Regional Water Council, that being “clean and abundant water for all within the Chattahoochee River Basin”. Sincerely, INTEGRATED SCIENCE & ENGINEERING, INC. L.H. (Dan) Davis, Jr., P.E. Project Principal Engineer CC: Jay Boren, Coweta County Water and Sewerage Authority Tai Yi Su, AECOM Attachment: Memorandum Report by AECOM, dated August 13, 2020
To: Coweta County Water and Sewerage Authority From: AECOM Date: August 13, 2020 Subject: Response to State of Alabama Comments to Coweta
County Water and Sewerage Authority’s District Plan Amendment Request
AECOM 1360 Peachtree Street, Suite 500 Atlanta, GA 30309 aecom.com
Memorandum
Coweta County Water and Sewerage Authority (CCWSA) submitted an amendment request on April 9, 2020, to the Metropolitan North Georgia Water Planning District (District) to incorporate its proposed Long-Term Water Supply Plan to the Water Resource Management Plan adopted by the District in 2017. This technical memorandum presents the responses to the comments submitted to the District by the State of Alabama, through its Office of Water Resources (May 15, 2020). CCWSA seeks to pump water from the Chattahoochee River into the B.T. Brown Reservoir to meet its projected long-term water demand through 2070.
Comment 1 Alabama Statement: “CCWSA’s proposal- which seeks to pump water directly out of the Chattahoochee River into BT Brown Reservoir and then discharge some of that treated wastewater back into the Flint River Basin….” “Since portions of Coweta County water are returned through sewer systems to both the Flint and Chattahoochee Rivers some estimate of future returns is needed. Though not a lot of information is provided as to future systems an assumption was made here that the same percentages from today would apply in the future.”
Response: The CCWSA plans to increase its wastewater treatment capacities in both Chattahoochee and Flint River Basins (see District Plan, Appendix B). The treatment capacity in the Chattahoochee River Basin is projected to increase from 0.16 MGD to 7.6 MGD by 2050. The treatment capacity in the Flint River Basin is projected to increase from 2.2 MGD to 6.0 MGD by 2050. Wastewater return to both basins is anticipated to increase in the future as development occurs. A large portion of the future water withdrawal increase is to meet the demands of potential industrial customers (economic reserve) and CCWSA anticipates that all industrial customers will be connected to sewers.
Technical Memorandum Response to State of Alabama Comments, Coweta County WSA District Plan Amendment Request Page 2 Table 1 presents the anticipated increase in wastewater return in 2050. Sewered need and plant capacity are based on maximum monthly flow (MMF). Details of the wastewater flow estimates are presented in the response to the Chattahoochee River Keeper.
As shown in the table below, the percentage of withdrawal returned to the Chattahoochee River is anticipated to reach approximately 52% in 2050. This is higher than what was estimated in Alabama’s analysis. There were several additional issues in Alabama’s calculations: 1) sewered need shown included flows from other entities in Coweta County, 2) septic flows quoted is an annual average quantity and should not be added to other flows presented on monthly average basis, 3) peak month withdrawal included groundwater withdrawals and supply for other utilities in Coweta County, 4) incorrect calculation of withdrawal returned to river because of the above.
Table 1. Estimating Return Flows for CCWSA Service Area1 (MGD)
2050 Estimates (MGD)
Sewered Need (AADF)1, 2 10.3 Sewered Need (MMF)1, 2 12.9
Plant Capacity in Flint (MMF)3 6.0
Plant Capacity in the Chattahoochee (MMF)3 7.6
Total Plant Capacity (MMF)3 13.6
Annual Average Demand4 (Chattahoochee Basin) 19.8 Wastewater Return Ratio5 52.0% % Sewered Capacity in Flint6 44.1%
% Sewered Capacity in Chattahoochee6 55.9%
% Returned to Flint7 22.9%
% Return to Chattahoochee7 29.1% Notes: 1 For CCWSA customers only. Sewered need from other entities in Coweta County is not included. 2 Based on the response to Comment 1 from the Chattahoochee River Keeper (projected 2050 annual average flow of 10.33 AAD-MGD) and a maximum month to annual average factor of 1.25. 3 Plant capacities from Appendix B, Metro North Georgia Water Planning District Water Resource Management Plan, June 2017 4 2050 annual average water demand, Table 5, Amendment Request from CCWSA, April 9, 2020 (including withdrawal from BT Brown with water pumped from the Chattahoochee River) 5 Annual average return divide by annual average withdrawal 6 Based on planned 2050 plant capacity 7 Assuming wastewater flow is returned to the rivers based on available sewer and plant capacities
Comments 2 and 3 Alabama Statement: “…the proposed interbasin transfer undermines the decision-making process….” “…the Corps will need to reconsider whether it has to make additional releases from Lanier and West Point Lakes to ensure that minimum flows are met downstream.” “Under the Corps’ current operations, minimum flows must be maintained below Jim Woodruff Reservoir (as measured at the gage near Blountstown, FL). Any additional water removed from the Chattahoochee River during a drought of record would require additional releases, which may be drawn from either Lanier or West Point or a combination of the two.”
Technical Memorandum Response to State of Alabama Comments, Coweta County WSA District Plan Amendment Request Page 3 Response: The State of Alabama’s comment refers to the “decision-making process” that led to the adoption of the new operations for the Apalachicola-Chattahoochee-Flint (ACF) River Basin in 2017. It is important to understand that the Corps operates five Federal reservoirs (Buford/Lake Sidney Lanier, West Point, Walter F. George, George Andrews, and Jim Woodruff) in the ACF Basin as a system. The three major storage projects in the ACF Basin (Buford/Lake Sidney Lanier, West Point, and Walter F. George) are operated to maintain their lake levels in the same zones concurrently. In other words, any effect on the river basin is shared equitably among the projects.
The schematic presented by the State of Alabama (Figure 1 (a)) does not reflect the system wide operations that actually occur in the ACF basin. The schematic in Figure 1 (b) reflects the accurate relationship between the reservoirs in the ACF system and the Blountstown gage on the Apalachicola River. Figure 1(b) shows that the wastewater return to Flint River contributes to the inflows to Lake Seminole (or Jim Woodruff Reservoir).
Figure 1 (a) and (b). Schematic Diagram of the ACF River System Related to this Analysis (Source: State of Alabama, May 2020). The Schematic from the State of Alabama is shown on the left (a), while the updated schematic is shown on the left (b).
Future wastewater return is projected to increase in both Chattahoochee and Flint Basins as CCWSA plans to expand wastewater treatment capacities in both basins (Appendix B, District Plan). The wastewater return to the Flint Basin is not lost; it will contribute to the consideration used by the Corps when balancing the operation of the ACF Basin. To meet minimum flows at Blountstown, FL, the Corps makes its release decision based on the composite conservation storage of all three major storage projects and the total basin inflow. Release would not be made specifically from Lake Lanier or West Point Lake alone as stated by the State of Alabama.
“During the drought of record in 2007, both Lanier and West Point were drawn down and the minimum flow was being discharged into the Apalachicola as data from the Blountstown Gage shows. Arguably the drought lasted considerably longer, which would show even greater impacts from the proposed withdrawal.” The drought of record (critical drought) for the ACF River Basin occurred in 2007-2008. The exact timing and duration of the drought may vary across the basin due to the hydrological and geographical features of the storage projects, and the meteorological conditions; we agree that any of the dates within the 2007-2008 period are generally characterized as drought conditions. During 2007-2008, both Lake Lanier and West Point Reservoir were drawn down in elevation in direct response to the drought conditions. In fact, all five Federal reservoirs in the ACF Basin would have been lower than normal due to the drought conditions.
Technical Memorandum Response to State of Alabama Comments, Coweta County WSA District Plan Amendment Request Page 4 Based on the current operating rule, only the minimum flow (5,000 cfs except when the system is in the Drought Zone) would be discharged into the Apalachicola River during a drought similar in magnitude and severity to the 2007-2008 drought. The minimum flow target below the Jim Woodruff Dam (as measured at the Blountstown gage) reflects the downstream end-result of system wide operations1. The Corps uses the composite zones to manage the lakes at the highest level possible while balancing the needs of all authorized purposes. The operation to maintain minimum flow targets below the Jim Woodruff Dam are based on the composite conservation storage of all the upstream reservoirs in the ACF System. Any potential drawdowns would be balanced across all five Corp projects, rather than solely reducing the storage at Lake Lanier or West Point Lake as stated by the State of Alabama.
Comment 4 Alabama Statement: “Impacts of projected withdrawals”, Analysis of the Proposed Chattahoochee River Withdrawal in Coweta County (May 2000), Attachment to the Comment Letter.
“… these comments are based in part on the attached report in which Alabama has attempted to quantify the impact to downstream river flows and reservoir levels that would result if the CCWSA’s proposal is approved.”
Response: Alabama’s analysis (Table 2 in the attachment of its comment letter, May 2020) used the maximum withdrawal rate to estimate downstream impacts. This method is flawed and the CCWSA would like to provide clarification. The maximum daily pumping rate is used for sizing pump station and transmission infrastructure. The simulated annual average pumping rate based on our safe yield model analysis is 13.4 MGD (approximately 63% of the maximum daily pumping rate for 2050) and 19.3 MGD (approximately 41% of the maximum daily pumping rate for 2070) for the period of record analyzed. Table 2 shows the maximum and average pumping rates from the Chattahoochee River under the 2050 and 2070 demand scenarios during the Period of Record (1/1/1965- 12/31/2017) and during the Critical Drought Period (2007-2008). In addition, pumping will not occur on days when the Chattahoochee River flow is below the Instream Flow Protection Threshold (IFPT), which will be set by Georgia Environmental Protection Division (EPD) to preserve downstream minimum flows. Pumping also will not occur if the B.T. Brown Reservoir is full and does not need to be refilled. Figure 2 shows that the proposed daily withdrawal quantities are significantly lower than the streamflow during the 2007-2008 drought conditions. Table 2. Maximum and Average Pumping Rates from the Chattahoochee River under the 2050 and 2070 Withdrawal scenarios during the Period of Record (1/1/1965- 12/31/2017) and during the Critical Drought Period (2007-2008)
Pumping from Chattahoochee Period of Record (1965-2017)
Pumping from Chattahoochee Critical Drought (2007-2008)
2050 2070 2050 2070 Maximum Daily Pump Capacity
Required (MGD) 21.3 47.4 21.3 47.4
Average Pumping Rate (MGD) 13.4 19.3 16.2 24.2
1 USACE Mobile District, Master Water Control Manual Apalachicola-Chattahoochee-Flint (ACF) River Basin, Revised March 2017
Technical Memorandum Response to State of Alabama Comments, Coweta County WSA District Plan Amendment Request Page 5
Figure 2. Flow at Chattahoochee River Intake Location vs Intake Withdrawal
Figure 3 demonstrates that the impacts of the proposed withdrawals will be minimal during drought conditions and will be insignificant during average and high flow conditions. The difference in the Chattahoochee River flow without pumping (pre-pumping as shown in blue) and with pumping (post-pumping as shown in red) is minimal during the 2007-2008 drought. The figure also shows that when the Chattahoochee River flow is below the IFPT, no pumping would occur. The IFPT will be set to maintain a minimum flows at all times to protect water quality, aquatic life, and downstream needs. There will be no withdrawal from the river when the streamflow at the proposed intake is less than the IFPT.
Figure 3. Simulated Chattahoochee River Flow Pre- and Post-Pumping – Max. Daily Withdrawal 47.4 MGD
Coweta County worked with the Georgia EPD to develop the target IFPT that will be consistent with the operation requirements of the ACF Basin. Because no withdrawal will be made when the streamflow is lower than the IFPT, water quality will be protected during low flow periods. The IFPT is set to consider downstream needs during critical low flow periods. Table 3 shows the IFPT approved by the EPD.
- 200 400 600 800
1,000 1,200 1,400
1/18
/200
7
4/28
/200
7
8/6/
2007
11/1
4/20
07
2/22
/200
8
6/1/
2008
9/9/
2008
12/1
8/20
08
MG
D
Flow at Chattahoochee River Intake Chattahoochee River Intake Withdrawal
Technical Memorandum Response to State of Alabama Comments, Coweta County WSA District Plan Amendment Request Page 6 Table 3. The Instream Flow Protection Threshold at Proposed Intake
Alabama’s calculation of downstream impact (Table 2 in the analysis attachment of its comment letter, May 2020) does not accurately account for 1) average withdrawal, 2) average wastewater return to the Chattahoochee River (as demonstrated in response to Comment #1). The estimated wastewater return can be calculated using updated % return shown in Table 1. In addition, the calculation for the reduction of average inflow into West Point Reservoir is irrelevant as the Corps does not make release decision based on inflow or storage in one single reservoir as stated previously.
CCWSA plans to implement water conservation measures and restrictions if Georgia EPD declares drought response. The objectives of drought response are to decrease overall system demand and to extend the available water supply during severe drought conditions. Lastly, the State of Alabama chose the 2007 August flow from the DSS files from the 2014 ACF Corps of Engineers Study at the West Point R Inflow “COE_CORR” in its calculation. One month of data does not accurately portray the operation of the reservoir system as a whole. The critical drought lasted from 2007 through 2008. Impacts to the basin should be evaluated over the period of records or the period of critical drought.
Conclusion The following is a brief summary of the analyses in response to the State of Alabama’s comments:
• The proposed withdrawal’s downstream impact is minimal as demonstrated in Figure 2 and Figure 3. • The simulated annual average withdrawal quantities for the period of record is significantly lower than
the maximum daily withdrawal quantity (this rate is used for sizing facilities). • Wastewater return to the Flint River Basin will contribute to inflows to Jim Woodruff Reservoir which
contributes to part of the composite storage considered by the Corps when making operation decisions to maintain minimum flows below the Jim Woodruff Dam.
• CCWSA plans to expand its wastewater treatment capacities in both Chattahoochee and Flint River Basins. Wastewater returns to both basins are anticipated to increase through 2050.
• The IFPT at the proposed intake location will be set to maintain minimum flows below the intake to protect water quality and needs of downstream users. No pumping will occur if the Chattahoochee River flow at the intake location is lower than the IFPT.
Month cfs MGD January 1,420 918 February 1,891 1,222
March 2,221 1,435 April 2,184 1,411 May 1,526 986 June 925 598 July 910 588
August 750 485 September 750 485
October 750 485 November 650 420 December 1,131 731
Coweta County Water Authority – WRM Amendment Request
Public Comments Received
1) Chattahoochee Riverkeeper
2) Middle Chattahoochee Regional Water Council
3) State of Alabama
4) City of Atlanta
1
May 15, 2020 Hon. Charlotte Nash, Chair, Governing Board Water Resource Management Plans Metropolitan North Georgia Water Planning District 229 Peachtree Street, NE Atlanta, Georgia 30303 Submitted via email to: comments@northgeorgiawater.com RE: Comments on Amendment Request submitted by: Coweta County Water and Sewerage Authority To the Honorable Charlotte Nash, Chattahoochee Riverkeeper appreciates the opportunity to submit the following comments on the Coweta County Water and Sewerage Authority’s (CCWSA) request to the Metropolitan North Georgia Water Planning District (District) for a “major amendment” to Appendix B of the 2017 Water Resource Management Plan (Plan). Established in 1994, Chattahoochee Riverkeeper (CRK) is an environmental advocacy and education organization with more than 10,000 members dedicated to making the Chattahoochee River a sustainable resource for the five million people who depend on it. Our mission is to advocate and secure the protection and stewardship of the Chattahoochee River, its lakes, tributaries, and watershed, in order to restore and preserve their ecological health for the people and wildlife that depend on one of the Southeast’s hardest working rivers. CCWSA’s amendment request anticipates a long-range plan for a new direct Chattahoochee River water withdrawal permit for 47.4 million gallon per day (MGD) from Georgia Environmental Protection Division (EPD) based on 2070 population served (221,226) and water demand. Such a permit has not been applied for or secured from EPD. When compared to current permits, this assumed permit would be the 12th largest permitted withdrawal in the Chattahoochee River basin, and on par with water withdrawal permits for Forsyth County (52 MGD with a current service population of 138,368) and the City of Gainesville (35 MGD with a current service population of 159,000). The amendment request’s short-range and more immediate ‘need’ (21.3 MGD) is for the year 2050, which conforms to the District’s current planning horizon. CCWSA intends to construct a new river withdrawal and pump station that would have the capability to secure the short-range need and have expansion capacity to meet the long-range plan.
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CRK cannot support the amendment in its current form or based on the available information for the following five reasons:
1. Wastewater Returns The amendment request does not clearly indicate where wastewater will be returned.
CCWSA vaguely states “a portion of the withdrawn water” will be returned “to surface waters within the county,” [Letter, p. 8] but not how much or to which major river basin. The District’s policy on return flows is not ambiguous in the Plan [https://northgeorgiawater.org/wp-content/uploads/2015/05/Water-Resource-Management-Plan_Amended-20190227.pdf]:
“Local wastewater providers should consider the need for returns of highly treated wastewater to local water bodies within the basin of origin,” [page 2-2]
EPD’s “planning guidance for this Plan further states that returning highly treated wastewater to” the Chattahoochee River watershed “shall be encouraged.” [2-2]
“Water use” in septic systems “is consumptive when it decreases the amount of water that is returned to surface waters. The District seeks to minimize consumptive uses to the extent possible, while also balancing other goals and considerations.” [Table 2-1, p. 2-4]
Local wastewater providers shall “Consider, where feasible, returning any water sourced from the Chattahoochee River Basin below Buford Dam or Upper Flint River Basin as highly treated wastewater to these basins when making future decisions regarding wastewater treatment plants and related sewer lines, pump stations and other conveyance infrastructure.” [Integrated-14: Encouraging the Return of Highly Treated Wastewater to the Chattahoochee and Flint]
When CRK had an early discussion with the applicant, they indicated the Chattahoochee withdrawals will either be sent via interbasin transfer to the Flint River basin or terminate in septic tanks in the short-term. The long-range plan apparently includes construction of a centralized wastewater treatment system with a discharge in the Chattahoochee River basin. However, that plan is not reflected in Appendix B of the Plan (Coweta Water, Summary of Planned Sources and Wastewater, pages 12-13) or described in this amendment request. The 2017 District Plan included a clear water return policy for the first time. This amendment request may be the first time the District has been presented with the opportunity to implement this policy and fulfill an intention to return water to its basin of origin. Additional detail on the final destination of water withdrawn from the Chattahoochee River is needed before the District can approve this amendment request.
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2. Population & Non-revenue Water Data
The amendment request seeks to alter the volume and location of CCWSA’s water withdrawal points within the Chattahoochee River basin. The population and non-revenue data raise a number of concerns and questions.
The population dynamics used to justify a short-range need for a 21.3 MGD withdrawal and long-range needs for a 47.4 MGD withdrawal are circumspect. For example, the 2017 District plan assumed a 2050 population in Coweta County to be between 247,779 and 256,038. The most recent Governor’s Office of Planning and Budget (OPB, 2019) numbers and the draft Atlanta Regional Commission (ARC) forecast put the 2050 population in Coweta County at much lower figures: 212,357 and 215,000, respectively. Looking back at previous projections, for example, in 2012 OPB anticipated Coweta County’s population in 2018 would be 155,486. The most recent U.S. Census estimate of the 2018 population was 145,864. 2000 2010 2018 2050 US Census Data & Estimates (Intercensal)
89,215 127,317 145,864
OPB 2012 Projections 155,486 OPB 2015 Projections 146,828 247,779 OPB 2019 Projections 144,823 212,357 District, Water Resource Management Plan (2017). See page 4-2.
256,038
ARC, The Atlanta Regional Plan Draft 2050 (October 2019)
215,000
The fluid data is particularly concerning given the Great Recession’s known historic effect on economic development and water supply planning. For example, EPD ultimately determined in 2016 that the Glades Reservoir in Hall County was “no longer part of any strategy to meet the water supply needs of the State” as a result of revised population and demand “projections.”1 Given the current COVID-19 conditions and their unknown effects on water supply operations and planning, it is highly probable that the region’s current public health and economic conditions will further reduce future population growth. The long-range 2070 withdrawal request may not be sustainable or perhaps even necessary. The April 9, 2020 letter (Letter) submitted on behalf of CCWSA with the major amendment request
1 Comment of the State Of Georgia on the Apalachicola-Chattahoochee-Flint River Basin Water Control Manual and Draft Environmental Impact Statement (October 2015), January 29, 2016, Page 9.
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suggests that if the population projections are indeed inflated and do not materialize, than the excess water supply will mitigate for climate change and reduced water availability. [page 2] This leads to the basic question: What is the real purpose and need for this withdrawal? CCWSA’s water loss audits also indicate a fluctuating non-revenue water loss rate that also tracks a fluctuating data validity score. The relatively high validity scores indicate general good management of data and water, but wide fluctuation in three audit years suggests a lack of consistency. Water Loss Audit Year Non-Revenue Water as % by
Volume of Water Supplied Water Audit Data Validity
Score 2016 4.2% 79 2017 9.2% 68 2018 7.1% 84
3. Demand Projections
The future demand projection for 60 gallons per capita per day in 50 years is an aspirational and laudable goal. However, the calculation used to reach this data point—based upon the Water Research Foundation’s report titled Residential End Users of Water, Version 2 Executive Report—makes two critical assumptions. [Letter, p. 3] First, that improved efficiencies will reduce demand. And second, that “more stringent plumbing codes” will be implemented in Georgia. While some improved efficiencies will likely occur on their own, in 2019 the Georgia Department of Community Affairs (DCA) rejected a well-crafted and reasoned District-led proposal to amend plumbing codes that would have dramatically reduced water use in metro Atlanta. Among the justifications DCA staff employed to table the proposal was a desire to keep such a proposal in reserve in case Georgia needed a bargaining chip in the on-going Florida v. Georgia U.S. Supreme Court challenge. Such a rationale and thinking suggest that if Florida fails to obtain a favorable verdict and equitable apportionment, than Georgia will see no need to alter the state’s plumbing code and reduce water use. Additionally, outdoor water use is significant component of residential use. How did the applicant calculate for outdoor water use and peak demands to reach future demand projections? With these considerations in mind, the CCWSA service area’s demand projection may be significantly under-estimated in this amendment request.
4. Diversion structure The withdrawal may require construction of a diversion structure or dam. Early discussion between CRK and the applicant indicated a diversion structure may be constructed across the
5
Chattahoochee River to direct water into the proposed raw water intake depending upon the selected location. The river already has multiple diversion structures that pose navigational hazards at municipal and power generation station withdrawal points. The proposed location could be upstream of between Georgia Power’s diversion structure at Plant Yates and a public boat ramp on the immediate Northside of Georgia Highway 16 (east of Whitesburg). Unfortunately, the new diversion structure could be less than 2 miles upstream of Plant Yates, which would render an existing and popular public boat ramp at Georgia Highway 16 in between of limited value. Over the last decade, numerous stakeholders have invested time and resources to improve recreational options and access in this section of the Chattahoochee River. The Chattahoochee Riverlands initiative—a partnership between the Trust for Public Land, the Atlanta Regional Commission, the city of Atlanta and Cobb County—proposes a recreation corridor that would transit this part of the Chattahoochee River. Specifically, Carroll County’s historic Moore’s Bridge Park and the Moore’s Bridge public boat ramp would function as the transition point between land and water for up/down stream access and a water trail. The proposed diversion dam could stymie the Riverlands’ plans, limit overall recreational options and use of this river section, and would introduce yet another navigational hazard to the Chattahoochee River.
5. Water Quality
For over 25 years, CRK has worked to improve the Chattahoochee River’s water quality and supply. Beginning in the 1970s, the state of Georgia’s policy was not to allow or permit direct municipal water withdrawals from the river between Atlanta and West Point Lake due to poor water quality. After the City of Atlanta was legally obliged to address chronic sewage and stormwater infrastructure failures and deficiencies, today’s average bacteria levels are 80 percent lower than in the 1990s. CRK is pleased that our organization’s advocacy has improved the Chattahoochee River’s quality to the point that CCWSA—and communities in south Fulton County—can even consider a municipal withdrawal that was unthinkable 50 years ago. However, according to Georgia’s Draft 2020 305(b)/303(d) Integrated Report (Water Quality in Georgia Report), the 21 miles of river where CCWSA’s withdrawal may be located are not meeting their water quality designation. The Pea Creek to Snake Creek, and Snake Creek to Wahoo Creek are designated for “fishing” and are impaired due to fecal coliform. What actions will be employed to improve the river’s water quality so the sections can be upgraded to a “drinking water” use to support a municipal water withdrawal?
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Conclusion CRK cannot support the amendment request in its current form because it is unclear if the water withdrawn will be returned to the Chattahoochee River basin; the population, non-revenue and water demand data raise a number of concerns; and the proposed withdrawal location may require construction of a new dam. If you have any questions, please contact me directly. Sincerely,
Chris Manganiello, PhD Water Policy Director cmanganiello@chattahoochee.org Direct line: 404.924.4509
May 15, 2020
Metropolitan North Georgia Water Planning District Water Resource Management Plans 229 Peachstreet N.E. Atlanta, Georgia 30303 comments@northgeorgiawater.comVIA EMAIL
Re: Proposed Amendment to MNGWPD’s Water Resource Management Plan
To whom it may concern:
The State of Alabama, through its Office of Water Resources, submits these comments on the amendment to the Metropolitan North Georgia Water Planning District’s Water Resource Management Plan that was recently proposed by the Coweta County Water and Sewerage Authority. For the reasons below, the District should reject the CCWSA’s proposed amendment.
First, the CCWSA’s proposal – which seeks to pump water directly out of the Chattahoochee River into BT Brown Reservoir and then discharge some of that treated wastewater back into the Flint River Basin – will harm Alabama, as well Georgia. As you know, the Alabama/Georgia border south of West Point is delineated by the Chattahoochee River. Many state-line cities, businesses and individuals rely on a dependable flow of water coming down the river. The proposed interbasin transfer here will negatively impact these local communities in a number of ways. For example, reduced downstream flows will result in fewer releases being made for hydropower generation at the various dams on the river, ultimately leading to higher electricity costs. Likewise, reduced flow will impair water quality. Not only will that hurt the river’s ecosystems and limit recreational opportunities, but it will make it more difficult for businesses with pollutant discharge permits to comply with those permits and attendant state water quality standards. These are just some of the adverse downstream effects – there are more – that would result if the CCWSA’s proposal is approved.
Second, the proposed interbasin transfer undermines the decision-making process that led the U.S. Army Corps of Engineers to adopting new operations for the
R.
OFFICE OF THE GOVERNOR
KAY IVEYGOVERNOR
ALABAMA DEPARTMENT OF ECONOMICAND COMMUNITY AFFAIRS
KENNETH W. BOSWELLDIRECTOR
STATE OF ALABAMA
Page 2 of 2May 15, 2020
ACF River Basin in 2017. One important decision the Corps reached as part of that process was to allocate additional storage space in Lake Lanier (which is part of the Chattahoochee River Basin) for water supply to ensure that metro Atlanta’s demands could be met. That decision was premised in part upon the Corps’ assessment that, notwithstanding that allocation, sufficient water would still flow downstream such that the impact on hydropower, the environment and other criteria would be minimal. The CCWSA’s proposal, if adopted, would call that assessment into question. Had the Corps accounted for the interbasin transfer, its determination very well may have been different, and the allocation may never have been approved. Thus, in the event that the District approves CCWSA’s proposal, the Corps’ allocation of storage space at Lake Lanier will need to be revisited. More specifically, the storage space allocated to Georgia’s direct withdrawals from Lake Lanier will need to be diminished by an amount that offsets the CCWSA’s withdrawal from the Chattahoochee and interbasin transfer into the Flint.
Third, in addition to revisiting the allocation at Lake Lanier, the Corps will need to reconsider whether it has to make additional releases from Lanier and West Point Lakes to ensure that minimum flows are met downstream. Under the Corps’ current operations, minimum flows must be maintained below Jim Woodruff Reservoir (as measured at the gage near Blountstown, FL). Any additional water removed from the Chattahoochee River during a drought of record would require additional releases, which may be drawn from either Lanier or West Point or a combination of the two.
Finally, these comments are based in part on the attached report in which Alabama has attempted to quantify the impact to downstream river flows and reservoir levels that would result if the CCWSA’s proposal is approved.
Sincerely,
J. Brian Atkins Division Chief Alabama Officer of Water Resources
JBA/jn
cc: Governor Kay Ivey Kenneth W. Boswell, ADECA Director
Attachment
1
Analysis of the Proposed Chattahoochee River Withdrawal in Coweta County
May 2020
This analysis was conducted using data from the application to the MNGWPD for revision of the
Coweta County water plan. To evaluate river and reservoir impacts DSS files from the 2014 ACF
Corps of Engineers study were accessed to obtain actual flows and elevations from 2007, the
drought of record. Because the Coweta County report presented data for 2050 and 2070, this
analysis computes the impact of those proposed withdrawals should a drought of record
reoccur.
Figure 1 Schematic Diagram of the ACF River System Related to this Analysis
2
Since portions of Coweta County water are returned through sewer systems to both the Flint
and Chattahoochee Rivers some estimate of future returns is needed. Though not a lot of
information is provided as to future systems an assumption was made here that the same
percentages from today would apply in the future.
Table 1 Return Flows
During the drought of record in 2007, both Lanier and West Point were drawn down and the
minimum flow was being discharged into the Apalachicola as data from the Blountstown Gage
shows. Arguably the drought lasted considerably longer, which would show even greater
(a) Sewered Needs 13.4
(b) Septic Flows 6.4
(c) Total wastewater 19.8
(d) Plant Capacity in Flint 13.5
(e) Plant Capacity in the Chattahoochee 18.4
(f) Total Capacity 31.9
(g) Total peak month withdrawal 37.1
(h) Withdrawal returned to river (a/g) 36.1%
(i) Sewered capacity in Flint (d/f) 42.3%
(j) Sewered capacity in Chattahoochee (e/f) 57.7%
(k)
% of withdrawal assumed to be
returned to the Flint (h*i) 15.3%
(l)
% of withdrawal assumed to be
returned to the Chattahoochee (h*j) 20.8%
Estimating Return Flows From Appendix B Coweta County - Wastewater
Notes: There is no change in the Draft Amendment
Wastewater numbers taken from the tables are 2050 Scenario 2
Withdrawal numbers taken from amended table monthly 2050
All values in mgd
3
impacts from the proposed withdrawal.
Figure 2 Lake Lanier Elevations 2007
Figure 3 West Point Elevations 2007
4
Figure 4 West Point Inflow By Month 2007
Figure 5 Flows at Blountstown, FL 2007
5
Table 2 Flow impact of withdrawals during drought of record
Under the Corps’ current operating plan minimum flows must be maintained below Jim
Woodruff Reservoir (as measured at Blountstown). Any additional water removed from the
river during the drought of record would require additional reservoir releases. That might be
drawn from Lanier or West Point or a combination of the two. The estimated amounts are
shown in Table 3.
Table 3 Potential Additional Draw in Reservoirs
2050 2070
Projected Chattahoochee withdrawals 21.3 mgd 47.4 mgd
Note: There are no existing permitted withdrawals
Withdrawal -21.3 mgd -47.4 mgd
Return 4.4 mgd 9.9 mgd
Net Change in Chattahoochee River Flows in mgd -16.9 mgd -37.5 mgd
Net Change in Chattahoochee River Flows in cfs -26.1 cfs -58.1 cfs
August 2007 West Point Inflow 1163 cfs 1163 cfs
% reduction of inflow into West Point Reservoir -2.2% -5.0%
Impact of projected withdrawals on River Flow
Return 3.3 mgd 7.2 mgd
Net Change in Flint River Flows in cfs 5.0 cfs 11.2 cfs
Net Change in Chattahoochee River Flows in cfs -26.1 cfs -58.1 cfs
Net Change in Flow at Blountstown -21.1 cfs -46.9 cfs
Loss from June 2007 thru November 2007 183 days (3,853) cfs-days (8,574) cfs-days
Storage between 1051 and 1052 at Lanier 14,923 cfs-days
Drop in Lanier to maintain Blountstown flow 0.26 feet 0.57 feet
Storage between 621 and 622 at West Point 8,268 cfs-days
Drop in West point to maintain Blountstown flow 0.47 feet 1.04 feet
Note: cfs/mgd 1.5473
Estimated drop in Reservoirs to maintain Blountstown Flow
Mikita K. Browning INTERIM COMMISSIONER
Keisha Lance Bottoms MAYOR DEPARTMENT OF WATERSHED MANAGEMENT
72 Marietta Street, NW Atlanta, Georgia 30303
C I T Y O F A T L A N T A
May 15, 2020 CERTIFIED MAIL 7018 0680 0001 9658 0261 Katherine Zitsch Director Water Resources Management Plans 229 Peachtree Street, NE Atlanta, GA 30303 Subject: Coweta Amendment Request Comments from City of Atlanta The City of Atlanta Department of Watershed Management (DWM) respectively submits our comments to the Coweta County Water and Sewerage Authority Amendment Request to the District’s Water Resource Management Plan. Background
The City of Atlanta and the Coweta County Water and Sewerage Authority (CCWSA) have a 20-year Interjurisdictional Agreement (IJA) that is scheduled to expire December 31, 2021. The contract may be renewed for two consecutive, separate 10-year terms. The IJA indicates Atlanta will provide CCWSA with a maximum of 2.8 mgd (2,000 gpm) beginning July 1, 2001; 6.6 mgd (5,000 gpm) beginning July 2005; and 11.8 mgd (10,000 gpm) beginning July 2010; and 22.2 mgd (20,000 gpm) beginning July 2020.
CCWSA is proposing a new Chattahoochee River water withdrawal to fill the existing BT Brown Reservoir which current receives inflow from Alexander Creek and pumped inflow from Cedar Creek. The BT Brown Water Treatment Plant (WTP) would be expanded and the existing connection to the Atlanta water system would be converted to an emergency only connection.
At this time, the City of Atlanta considers the CCWSA amendment request to be premature and potentially ill-advised. The City’s rationale behind this position and our concerns for the possible water withdrawal are detailed below.
Water Withdrawal Near Major Effluent Discharges
Approval of a new water withdrawal for CCWSA will mean withdrawing raw water downstream of, and relatively close to, the existing effluent discharge locations for all the
Coweta Amendment Request Comments from City of Atlanta Page 2 City’s effluent discharge locations. It is difficult to assess the exact impact without knowing where CCWSA intends to locate the withdrawal. The City’s major wastewater treatment plant, the R.M. Clayton Water Reclamation Center (WRC) discharges effluent into the Chattahoochee River immediately downstream of its confluence with Peachtree Creek. Effluent discharge from the City’s second largest treatment plant, the South River WRC, is pumped across the Eastern Continental Divide to discharge into the Chattahoochee River further downstream. Finally, effluent from the City’s third treatment plant, the Utoy WRC, is discharged into the Chattahoochee River just downstream from the South River discharge location. NPDES permitted flows for these major wastewater treatment plants are listed in Table 1. It should be noted that the City discharges more effluent back into the Chattahoochee River than is withdrawn by the City at its raw water intakes. In 2019, the daily average withdrawal totaled approximately 32.7 million gallons but the WRCs returned treated wastewater totaling roughly 48.4 million gallons.
Table 1. Atlanta WRC NPDES Permitted Effluent Discharge Flows
Treatment Plant Name Permitted Monthly Average Daily Flow
(mgd)
Permitted Weekly Average Daily Flow
(mgd)
R.M. Clayton WRC 100 125
South River WRC 48 60
Utoy Creek WRC 40 50
Totals 188 235
In addition to WRC effluent discharges to the Chattahoochee River, the City’s West Area Water Quality Control Facility (WQCF) discharges to the Chattahoochee River immediately downstream of the confluence with Peachtree Creek. The West Area Combined Sewer Facilities includes the West Area WQCF and three Combined Sewer Control Facilities (CSCFs). The Clear Creek CSCF discharges to Clear Creek; the North Avenue CSCF discharges to an unnamed tributary to Proctor Creek; and the Tanyard Creek CSCF discharges to Tanyard Creek. These creeks ultimately feed the Chattahoochee River. During dry weather, the combined sewer sub-basins deliver flow to the downstream sanitary trunk sewer systems for delivery of water to the WRCs. When wet weather events cause flow to exceed the capacity of the downstream sewer system, excess flow is automatically routed by gravity to the CSCFs. Each CSCF provides screening and delivers the first flush and ongoing combined sewer flows to the West Area Tunnel for storage/conveyance to the downstream West Area WQCF. The West Area WQCF provides equivalent primary treatment to remove settleable solids, disinfect, and dechlorinate the flow. Flows exceeding the WRC, WQCF, and tunnel capacity are discharged to local creeks through the CSCFs. The CSCFs provide minimum treatment with the first flush already captured within the tunnel, and the flow to be discharged to
Coweta Amendment Request Comments from City of Atlanta Page 3 the receiving waterbody undergoes screening, disinfection, and dechlorination prior to discharge.
Siting a drinking water withdrawal within a relatively close stream travel time to these major effluent discharge locations reduces the mixing time within the Chattahoochee River available to assimilate and diffuse remaining pollutants within the discharges. In effect, such siting may be considered to create a potential situation of defacto, non-engineered potable reuse where the effluent discharged from the City’s wastewater treatment plants is used for drinking water purposes after withdrawal from the Chattahoochee.
Water Quality Concerns
Siting a drinking water intake in proximity to such significant upstream pollutant discharges will require a detailed source water assessment to evaluate the suitability of a downstream Chattahoochee River to serve as a raw water intake location. Such a study should include a temporal assessment of microbiological, physical, and chemical parameters. Allowing an amendment of the Water Resource Management Plan is believed to be premature until such technical studies can be completed to demonstrate such suitability. It is anticipated that an instream mixing study will be required to supplement water quality modeling of the Chattahoochee River under various stream flow conditions during both drought and high flow conditions.
The City believes that CCWSA should be required to perform the analytical analysis, including water quality dispersion modeling of the discharges from Atlanta’s WRCs to determine any impact to raw water quality at the proposed intake rom the Chattahoochee River as proposed by CCWSA. Such analysis must demonstrate that CCWSA’s proposed withdrawal will not require Atlanta to upgrade the City’s WRCs. If there are water quality concerns that arise from the modeling or other assessments, CCWSA should provide a study on the water treatment processes required to provide safe, reliable drinking water.
Future Impacts on Effluent Discharge Limitations
The City is also concerned with potential future budgetary and technical operational impacts on the WRCs, WQCFs, and CSCFs. Siting a raw water intake downstream of these effluent discharge locations may be expected to result in more stringent effluent discharge limitations thus creating significant additional technological and budgetary challenges for the City to upgrade its treatment facilities. Even now, it has become increasingly difficult for the City to meet the ever more stringent effluent limitations. Current weekly average limitations for biochemical oxygen demand (BOD) is 8.2 mg/L; total suspended solids (TSS) is 10 mg/L; chemical oxygen demand (COD) is 45 mg/L; ammonia as N is 1.8 mg/L; and phosphorus is 0.5 mg/L. The WRCs have at times been challenged to meet the ammonia and phosphorus limits, especially during extreme wet
Coweta Amendment Request Comments from City of Atlanta Page 4 weather events or during operational disruptions. Similarly, the CSCFs have been challenged to meet fecal coliform limits during wet weather events. Available land to site new treatment processes and upgraded facilities is limited as development occurs surrounding each treatment site. Sophisticated technology required to remove pollutants to lower and lower detection levels is expensive both to build and to maintain both in terms of capital expenditures and operational budgets.
While the City has been generally able to meet current effluent limitations, as these limitations become more stringent, any potential disruption in normal plant operations or typical influent concentrations becomes more challenging to meet. The existing permit for the combined sewer facilities is requiring site-specific studies for metals and an approvable total recoverable water-effect ratio (WER) analysis for the total recoverable and dissolved cadmium, copper, nickel, lead, and zinc. If WRC effluent effectively becomes defacto reuse water, similar additional permit requirements for further studies and more stringent limitations become more likely, all of which will cause greater budgetary impacts on sewer rates.
Further, during emergency situations caused by more extreme weather conditions that are expected due to adverse climate change impacts, the facilities may not be capable of meeting either current or the more stringent discharge limitations. Thus, CCWSA may be at risk of shutdown of the new water withdrawal during such potential emergency conditions.
Water Supply Watershed Designation
In addition to anticipated more stringent effluent limitations at the City’s treatment facilities, other property owners adjacent to the Chattahoochee River upstream of the new water withdrawal location will be affected. The watersheds adjacent to the new withdrawal location will become water supply watersheds and thus will become subject to more stringent nonpoint source controls required to protect such withdrawal locations from pollutant loads. Each water supply watershed will need to identity both point source and nonpoint source dischargers that have the potential to adversely impact water withdrawals. Those dischargers will, in turn, need to address identified risks either through increased regulatory requirements or implementation of best management practices.
Near-Term CIP Projects Serving the South Fulton Service Area to Exceed $200 Million
Atlanta has in good faith planned short-term, intermediate, and long-term Capital Improvement Program (CIP) projects to provide adequate, quality drinking water services to its entire service area. Relative to the south Fulton service area that includes the two connections to the CCWSA system, the City has in excess of $200 million of near-term CIP projects detailed in the 2020 Water Master Plan that are designed to serve projected growth in the area. These near-term CIP projects are detailed in Table 2.
Coweta Amendment Request Comments from City of Atlanta Page 5 The project listing of planned CIP projects in Table 2 only shows planned CIP projects through 2030. The City’s 2020 Water Master Plan also includes significant CIP expenditures during the intermediate and long-term planning periods through the Year 2040 and 2060, respectively. It is noteworthy that one of these major CIP activities is an option to develop a new water treatment facility to further ensure adequate service and system resiliency for the south Fulton area. The facility would transport water from the current Chattahoochee River withdrawal to the proposed new facility. Due to the distances involved, the City is also considering a raw water intake further downstream and has included a feasibility assessment as a short-term project (Project WA-WR-RI-NT-01) as listed in Table 2 on the next page. While this is currently considered a secondary option, the City is considering initiating the planning necessary to determine the feasibility of installing another Chattahoochee River withdrawal. The cost assessment will also consider the projected impacts on the City’s wastewater facilities. The difference in a proposed Atlanta raw water withdrawal from a CCWSA water withdrawal is that Atlanta would be able to offset the additional costs of wastewater improvements with additional revenue from the water and sewer charges.
No siting location has been identified for either of the options at this juncture. Siting considerations will include evaluating the costs of transmitting water from the current raw water intake versus the costs of installing a new intake further south. Further, the costs of adding more processes to the possible drinking water plant will be evaluated in terms of the costs, and feasibility, of additional wastewater processes at each of the WRCs.
Inter Basin Transfer Ramifications
While all Atlanta wastewater is discharged back to the Chattahoochee River Basin, CCWSA has several wastewater treatment plants discharging to the Flint River Basin. According to the Plant Capacity at End of Period table in the CCWSA amendment request, Year 2025 flows of 7.3 mgd of the 18.3 mgd total capacity, or 40 percent, of the flow will be discharged to the Flint River Basin. With the current “water war” situation between the States of Georgia, Alabama, and Florida, it is expected that at least Florida and possibly Alabama will object to any flow diversion from the Chattahoochee River Basin. Should CCWSA be forced to pump effluent discharges back to the Chattahoochee River, this will be an additional cost to CCWSA. The adjacent states are also expected to object to this new withdrawal as an “additional” amount to be withdrawn since the City’s withdrawal remains the same.
Coweta Amendment Request Comments from City of Atlanta Page 6
Table 2. Near-Term CIP Projects to Serve the South Fulton Service Area
Project ID Project Name Purpose Cost (2019 Dollars)
WA-DS-OT-NT-01 Chattahoochee-Adamsville Redundant Main
Resiliency for critical water main supplying South Fulton through the Adamsville Repump Station.
$ 28,000,000
WA-DS-OT-NT-02 Adamsville-Fairburn Road Redundant Mains
Resiliency for critical water main supplying South Fulton through the Adamsville Repump Station.
$ 30,150,000
WA-DS-OT-NT-04 Hartsfield Fill Line Redundant Mains
Resiliency for critical water mains supplying South Fulton through the Hartsfield Repump Station.
$ 33,300,000
WA-DS-OT-NT-05 Sullivan Road 24” Redundant Main
Resiliency for critical water mains supplying South Fulton through the Hartsfield Repump Station.
$ 5,250,000
WA-DS-OT-NT-18 Southwest Fulton Piping Loop and Flusher Improvements
Improve local water quality on the extreme southwestern end of system with new loops, reducing the size of underutilized pipes, and boosting a nearby auto flusher.
$ 7,450,000
WA-DS-OT-NT-19 Northside Drive Central Main
Provide capacity to support other proposed mains heading south from the Hemphill WTP.
$ 13,900,000
WA-DS-OT-NT-20 Northside Drive South Main
Boost filling support for Hartsfield Repump Station to minimize low pressures as it works to support growing South Fulton demands.
$ 46,600,000
WA-DS-OT-NT-25 Cascade Road Main
Extend part of Project WA-DS-OT-NT-02 toward the Hemphill WTP to boost South Fulton pressures, especially during emergencies.
$ 43,800,000
WA-WR-RI-NT-01 Adamsville-Hartsfield Service Area Long Term Supply Plan
Source water assessment, feasibility assessment, and conceptual planning for a South Fulton WTP.
$ 780,000
Total: $209,230,000
Coweta Amendment Request Comments from City of Atlanta Page 7 Thank you for your consideration of the points raised in this letter. If you have any questions or need additional information, please contact me at 404-546-3333 or mbrowningl@atlantaga.gov. Sincerely,
Mikita K. Browning Interim Commissioner Department of Watershed Management Copies: Jac Capp, Watershed Branch Chief, Georgia Department of Natural Resources Carmen Chubb, Chief of Staff, Office of the Mayor Joshua Williams, Chief Operating Officer, Office of the Mayor Todd Hill, Deputy Commissioner, Office of Watershed Protection Quinton T. Fletcher, Deputy Commissioner, Office of Water Treatment & Reclamation Rob Bocarro, Deputy Commissioner, Office of Engineering Services Darren Boykin, Deputy Commissioner, Office of Linear Infrastructure Operations Roger Bhandari, Division Chief, Watershed, Department of Law
Coweta County Water Authority – WRM Amendment Request
Letter of Support from the Coweta County Delegation Members
Villa Rica, GA Amendment Request
TO: Executive Committee FROM: Metro Water District Staff DATE: August 26, 2020 RE: Plan Amendment Process Documentation and Staff Recommendation
(Villa Rica, GA) ________________________________________________________________________ The Metropolitan North Georgia Water Planning District received a request from the City of Villa Rica to modify the Water Resource Management Plan. According to the Plan Amendment Guidelines adopted by the Board on August 28, 2013, District staff is required to provide the Executive Committee a category recommendation concerning the plan amendment request prior to the meeting. The staff recommends the following change outlined below: Amendment Request: Appendix B, Douglas County - Water Local Jurisdiction: Villa Rica, GA Description: The City of Villa Rica requests that Appendix B, Douglas
County - Water be revised to demonstrate an increased water supply and water treatment capacity for the Lake Paradise/Cowans Lake and Franklin Smith Water Treatment Plant. Additional background is provided in the attached letter.
Staff Recommendation: District staff recommends this request be categorized as a
major amendment and subject to a 30-day public comment period because modification of the plan is local in nature but may be objected to by other local parties.
Mr. Daniel E. Johnson, P.E. August 7, 2020
Attachment 1
Proposed Changes to 2017 Water Resources Management Plan
Douglas County ‐ Water
Summary of Planned Sources
Monthly (Note 1) Peak Day
DDCWSA
DDCWSA
Villa Rica 0.5 0.6
23.4 31.2
Summary of Needs
Scenario 1 Scenario 2 Scenario 1 Scenario 2
23.9 24.4 32.0 34.7
18.9 19.4 22.0 24.7
Scenario 1
2025 (AAD‐
Scenario 2
2025 (AAD‐
Scenario 1
2050 (AAD‐MGD)
Scenario 2
2050 (AAD‐MGD)
Notes: 11.8 12.1 13.8 15.4
(3) Peak day is 1.6 times annual average day.
(4) Scenario 2 is being used for the phasing plan below.
Phasing Plan
DDCWSA Bear Creek WTP
Villa Rica Franklin Smith WTP (Note 6)
Total Capacity (PD‐MGD)
Notes:
Capital Projects
Non‐Capital Programs
Total Projected Demand from Facilities (AAD‐MGD)
Chattahoochee Basin
23.0 23.0 30.6
Facilities (Note 5)
Existing (2016) By 2025 By 2050
Permitted Plant Capacity
(PD‐MGD)
Plant Capacity at End of Period
(PD‐MGD)
Plant Capacity at End of Period
(PD‐MGD)
N/A
The following non‐capital programs are specific to Douglas County. These programs are in addition to those that apply to all counties
within the Metro Water District.
Determine required improvements to accommodate routine purchase of 10 PD‐MGD from CCMWA or expand existing plant capacity.
Maintain interconnections and water supply agreements with Cobb County Water System.
31.2
Tallapoosa Basin
1.5
(6) The Villa Rica Franklin Smith WTP is located in Carrol County and provides water to areas outside Douglas County that are not included
in these projections.
1.0 0.6
(5) The schedule shown above is intended to be a general guideline to identify general expansion needs. Expansion capacity may be
required sooner or later than indicated depending on local population and employment growth, water service extensions and other
planning variables. Specific conditions for withdrawal and operation permits will be determined by Georgia EPD.
24.5 24.0
23.0 30.6
From CCMWA ‐5.0 ‐10.0
Total Withdrawal (MGD) 24.5
Lake Paradise/Cowens Lake
23.0
1.5
Dog River Reservoir
Source
Local Water
Provider
Current Permitted Withdrawal
Monthly Average (MGD)
Treatment Capacity (Note 4) 24.0
Notes:
(1) Monthly average day is 1.2 times annual average day.
Water Demands & Capacities
2025 Peak Day (Note 3)
(PD–MGD)
2050 Peak Day (Note 3)
(PD–MGD)
(2) Bear Creek Reservoir is a supplemental source to Dog River with a monthly permit limit of 6.4 MGD that is used to maintain in‐stream
flow.
Douglas County Needs
31.2
Planned 2050 Withdrawal (MGD)
Total Projected Demand from Facilities (PD‐MGD)
Bear Creek Reservoir (Note 2)
PAGE 16
JUNE 2017WATER RESOURCE MANAGEMENT PLAN
METROPOLITAN NORTH GEORGIA WATER PLANNING DISTRICT
Mr. Daniel E. Johnson, P.E. August 7, 2020
Attachment 2
Referenced Tables from 2009 Water Supply and Water Conservation Management Plan
Mr. Daniel E. Johnson, P.E. August 7, 2020
Attachment 3
City of Villa Rica Population and Water Use Projection Technical Memo
TECHNICAL MEMORANDUM DATE: August 4, 2020 TO: Mr. Tom Barber, City of Villa Rica FROM: Alex Wiseman, P.E., Lindsey Fields, Ph.D. RE: City of Villa Rica Water Demand Forecasts and Water Supply Needs through 2065 C & S Project No.: V8150.001 Introduction The City of Villa Rica, located in both Carroll and Douglas Counties, provides water service to 6,731 water customers. In support of their request to amend the 2017 Metropolitan North Georgia Water Resources Management Plan to more accurately reflect the City’s future anticipated water needs, the City requested an updated forecast of water demands and water supply needs through 2065. This Technical Memorandum provides the methodology and results of the long-term water demand flow forecasts for the City through 2065.
Population Forecasts Population growth is directly linked to additional water supply needs. Except for industrial manufacturing or processing, water demands are directly related to the population served. Historical population data from the decennial census from 1970 through 2010 were obtained, along with population estimates for years 2011 through 2018 developed by the US Census Bureau. The Georgia Office of Planning and Budget (OPB) develops population projections for each County in Georgia. OPB last published population projections in 2015. The population forecast for Douglas and Carroll Counties through 2062 was obtained from OPB. The OPB develops population forecasts only at the county level. To estimate the city level population, census tract areas within the county are used to break down the county population to the city level. The population located in each tract is then forecast through 2065 using the same combined average growth rate as Douglas and Carroll Counties. Because the City of Villa Rica is located in two counties, population data for Carroll and Douglas Counties were added together for regression analysis of population growth trends. The underlying assumption to this method is that the percentage of the County population located in Villa Rica remains constant through 2065. From 1990 – 2018 when Census/OPB data were available, the City of Villa Rica comprised an average of 5.2% of the total combined population of Carroll and Douglas Counties; therefore, it
City of Villa Rica; Technical Memo August 4, 2020 Page 2
was assumed that the population of Villa Rica remained consistently 5.2% of the combined county population through 2065. This method may underestimate population since the growth rate may be higher inside the City and the City may choose to annex land in the future. The City’s population forecast through 2065, needed to assess water supply needs, was extrapolated based on the same growth rate as the OPB-based forecasts of Douglas and Carroll Counties. Since the Villa Rica water system serves the entire City and no surrounding areas it was assumed that the City’s entire population is served by the water system. Figure 1 presents historic population data from 1990 through 2018, OPB forecasts through 2060 and the extrapolated forecast through 2065. Figure 1. City of Villa Rica Historic and Projected Population
As seen in Figure 1, the population of Villa Rica, and thus the population served by the City’s water system, is expected to increase from 15,541 people in 2018 to 24,537 in 2065, increasing by approximately 58% over the ±50-year timespan. Table 1 provides a summary of the population forecasts. According to the U.S. Census Bureau’s 2018 Population Estimates for Douglas and Carroll Counties, the number of people per household is 2.87 and 2.73, respectively for an average of 2.8 people per household.
400
5,400
10,400
15,400
20,400
25,400
30,400
1990 2000 2010 2020 2030 2040 2050 2060 2070
Popu
latio
n
Year
Historic Population OPB-Based Population Forecast Extrapolated Forecast
City of Villa Rica; Technical Memo August 4, 2020 Page 3
For
ecas
ts
Table 1. Historical Population and Population Forecasts
Year Douglas + Carroll
Counties City of Villa
Rica
1970 74,063
1980 110,919
1990 142,542 3,942
2000 179,442 4,356
2010 242,930 14,066
2011 244,514 14,102
2012 245,551 14,268
2013 248,734 14,438
2014 253,119 14,703
2015 257,504 14,896
2016 261,888 15,108
2017 266,273 15,304
2018 270,658 15,541
2019 275,122 14,311
2020 279,586 14,543
2021 284,051 14,775
2022 288,515 15,007
2023 292,979 15,240
2024 297,525 15,476
2025 302,072 15,713
2030 324,853 16,898
2035 347,812 18,092
2040 371,136 19,305
2045 395,096 20,551
2050 420,073 21,850
2055 410,435 21,349
2060 437,600 22,762
2065 471,728 24,537
City of Villa Rica; Technical Memo August 4, 2020 Page 4
Water Demand Forecasts Developing water demand forecasts requires several steps, including gathering data from the City to assess historic consumption patterns and develop metrics, or statistics related to historic usage. These metrics are then used in conjunction with population forecasts to develop demand forecasts through 2065. The process and data assessment to develop water demands is discussed below. Water System Overview The City of Villa Rica provides water to customers within the City limits. Based on water system records, the City of Villa Rica currently provides water service to 5,918 residential customers, 630 commercial customers, 50 industrial customers, and 133 irrigation customers. Approximately 88% of the customers are residential, and an average of 60% of water demand is residential. For population and water demand forecasts, it is assumed that the city limits and the current service area remain unchanged through the planning period. The City of Villa Rica currently obtains its water supply from two surface raw water sources, Lake Fashion and Cowan’s Lake in the Tallapoosa River Basin, which have a total combined permitted withdrawal capacity of 1.5 MGD (monthly average; Permit No. 022-1302-04). The City’s main withdrawal is Lake Fashion. The City also purchases water from Carroll County at a current maximum purchase rate of 2.4 MGD. When the water purchasing contract expires in March 2025, the maximum purchase rate will decrease by an amount to be determined by Carroll County. Water System Metrics Historic water consumption patterns play a key role in forecasting future water needs. Records of Total Authorized Consumption and additional data reported as part of the City’s annual Water Loss Audits provide insight into water use. The data provided for analysis included the total authorized consumption and customer counts from 2015 – 2019. The City provided daily water withdrawals records, daily water purchased data, water consumption data, and customer breakdowns for years 2015 – 2019 as well as water loss audit data from 2015 – 2019. This data set provides the total amount of water delivered by the system by customer type. These datasets were reviewed and analyzed to develop water metrics for forecasting future water demands. Each metric is discussed below. Historic Water Demands. Over the past 5 years, the average billed water consumption increased from 1.19 MGD to 1.27 MGD. Over the past 5 years the residential water consumption is approximately 60% of the billed water consumption, commercial water consumption is approximately 28% of the billed water consumption, industrial water consumption is approximately 10% of the billed water consumption, and irrigation is approximately 3% of the billed water consumption. Table 2 presents an overview of billed water consumption for 2015
City of Villa Rica; Technical Memo August 4, 2020 Page 5
through 2019 as well as total water supplied. The values for Billed Water Consumption do not include unbilled authorized water use or unmetered authorized water use. Table 2. Historic Water Demands
Year
Billed Water Consumption (MGD)
Residential Commercial Industrial Irrigation Total Water Supplied
(MGD) 2015 0.72 0.31 0.13 0.03 1.19 1.55 2016 0.77 0.35 013 0.04 1.29 1.59 2017 0.72 0.32 0.10 0.03 1.17 1.67 2018 0.75 0.35 0.13 0.03 1.25 1.72 2019 0.75 0.36 0.13 0.03 1.27 1.83
Average Percentage of
Total Billed Water Consumption
60% 28% 10% 3% 100%
Non-Revenue Water Estimate. In all water systems, there is a component of the water pumped to the distribution system that is unaccounted for. This unaccounted-for water, or non-revenue water (NRW), results from legitimate water uses, such as fire-fighting or construction, as well as losses such as leaks or faulty meters in the distribution system. The difference in what is billed versus what is supplied to the system provides an indication of non-revenue water. Per EPD compliance requirements, the City of Villa Rica conducts an annual water audit to estimate non-revenue water. The water audits indicate an average water loss of 15.2% from 2015 – 2019. The City continues to work to reduce non-revenue water in the system. Per Capita Water Usage Rates. The water usage rate per person is one of the key metrics to forecast future water use. The water use per person per day was calculated for 2015 – 2016 using the City’s residential water consumption for each year divided by the population served as reported in the City’s Water Loss Audits. Table 3 provides an overview of the per capita rates for these years and an overall average per capita water usage. Table 3. Residential Per Capita Water Usage Rates
Year Water Usage per Person (gallons
per capita per day, gpcd) 2015 51.4 2016 54.9 2017 51.4 2018 47.7 2019 48.1
Average 50.7
City of Villa Rica; Technical Memo August 4, 2020 Page 6
The residential per capita water usage rates are typical for the region and consistent with the national average single-family indoor water end uses as reported by the Water Research Foundation (2016). The average per capita rate for the 5-year period is 50.7 gpcd, which will provide the initial basis for the water demand forecasts. However, as existing and future housing stock implements the more efficient plumbing code standards, the per capita rate is expected to decline. For consistency with the Middle Chattahoochee Regional Water Plan, the per capita rate will be reduced over time as shown in Table 4 consistent with adjustment factors used for Carroll County as reported in the Water and Wastewater Forecasting Technical Memorandum – Middle Chattahoochee dated February 2017. Adjustment factors for Douglas County were not used because the data were not publicly available. Table 4. Plumbing Code Per Capita Rate Adjustment over Planning Period
Year
Adjustment Factor from Current Per
Capita Rate Per Capita Rate
(gpcd) 2015 1 50.7 2020 0.99 50.3 2025 0.99 50.0 2030 0.98 49.6 2035 0.97 49.3 2040 0.97 48.9 2045 0.96 48.6 2050 0.95 48.2
The overall per capita rate for Carroll County presented in the Middle Chattahoochee Regional Water Plan is currently 144.0 gpcd for municipally supplied water in 2020 and the baseline overall per capita rate for Douglas County presented in the Water Resources Management Plan for the Metropolitan North Georgia Water Planning District is currently 90 gpcd, both of which are higher than the City of Villa Rica. Maximum Day Demand. Maximum day water demand is an important consideration for planning water infrastructure. Water withdrawals, including the City’s, are based on the maximum day need. Daily raw water withdrawal reports and records of daily water purchased from Carroll County were provided by the City for 2015 – 2019 and an average peak to annual average day ratio of 1.3 was calculated. The estimated peak-to-average day ratio of 1.3 falls within the typical range for smaller water systems. Water Demand Forecasts From 2015 – 2019 the City’s Water Loss Audits report that an average of 97% of the total City population was served by the water system. Therefore, to calculate the water demand forecast it was assumed that 97% of the projected population would consistently be served by the City’s water system. The average residential water usage rate of 50.7 gpcd is applied to the served population forecast through 2020, when it is reduced as shown on Table 4 to account for reductions due to incorporation of the more efficient plumbing code standards. Total water demand was calculated
City of Villa Rica; Technical Memo August 4, 2020 Page 7
assuming the percentage of residential water demand remains a consistent 60% of total overall water demand as described above and shown in Table 2. Predicting future commercial, industrial, and irrigation water demands is difficult as many factors impact whether an industry will move to a given area and the amount of water that is required to support the industry. It should be noted that using the total per capita rate is not an effective way to estimate future growth of the industrial sector. To provide the City with flexibility and agility to meet future needs should an industry desire to locate or increase its water supply needs, a reserve capacity is added to the water demand forecasts. The reserve capacity allows Villa Rica to be prepared for economic development opportunities when they arise, as well as any additional associated increases in the residential population in the water service area. The reserve capacity is set to 5% of the total demand beginning in 2025 and then increases to 15% in 2055 as the uncertainty increases farther out on the planning horizon. Industrial water demand is held at a consistent 10% of the total water demand until 2025, and then an additional industrial component of 2% is added to account for potential future industry. Irrigation water demand is held at a constant 3% of the total water demand throughout the entire water use projection. Historic water demands including the estimates for non-revenue water as well as water demand forecasts are summarized and presented in Table 5 and Figure 2 below. The maximum day water demand is forecast to be approximately 3.34 MGD in 2065. Table 5. Historic and Projected Water Demands by Customer Category (MGD)
Year Residential Commercial Industrial Irrigation Reserve Total AAD Max Day
2016 0.76 0.35 0.12 0.03 0.00 1.26 1.66 2017 0.85 0.39 0.14 0.04 0.00 1.41 1.85 2018 0.93 0.43 0.15 0.04 0.00 1.54 2.03 2019 0.87 0.40 0.14 0.04 0.00 1.45 1.91 2020 0.82 0.38 0.13 0.04 0.00 1.37 1.80 2021 0.83 0.38 0.14 0.04 0.00 1.39 1.82 2022 0.85 0.39 0.14 0.04 0.00 1.41 1.85 2023 0.86 0.39 0.14 0.04 0.00 1.43 1.88 2024 0.87 0.40 0.14 0.04 0.00 1.46 1.91 2025 0.88 0.40 0.14 0.04 0.07 1.54 2.02 2030 0.94 0.43 0.16 0.04 0.08 1.65 2.16 2035 1.00 0.46 0.17 0.04 0.25 1.92 2.52 2040 1.06 0.49 0.18 0.05 0.27 2.04 2.67 2045 1.12 0.51 0.19 0.05 0.28 2.15 2.82 2050 1.18 0.54 0.20 0.05 0.30 2.27 2.98 2055 1.16 0.53 0.19 0.05 0.29 2.22 2.91 2060 1.23 0.57 0.21 0.05 0.31 2.37 3.10 2065 1.33 0.61 0.22 0.06 0.33 2.55 3.34
Note: Water demands include Non-Revenue Water estimates.
City of Villa Rica; Technical Memo August 4, 2020 Page 8
Figure 2. Historic and Projected Water Demands
The next step in the planning process is to identify any potential gaps in existing water supply and future water needs. Water supply and treatment capacity is permitted on a maximum day basis. Figure 3 compares the maximum day water demand forecasts to the maximum day water supply available from existing sources. The current existing sources include maximum withdrawals from the City’s existing permitted raw water withdrawals and water purchased from Carroll County. Figure 3 below shows the City’s available water supply with current and future forecasted water demands. Water purchased from Carroll County or any other potential wholesale water sources have been excluded from Figure 3 below because although the City has purchased potable water from Carroll County, there is no long-term water supply contract between the City and the County. The City is currently able to meet its daily average water demands using it’s own raw water sources and supplements for peak demand needs by purchasing water from Carroll County. Based on the forecasted water demand, the City will continue to be able to supply it’s own average daily water demand until 2025, at which time they will need to expand their own raw water supply or supplement their existing water source with purchased water.
0.00
0.50
1.00
1.50
2.00
2.50
3.00
3.50
Wat
er D
eman
ds (M
GD)
Year
Average Day Demand Peak Day Demand
City of Villa Rica; Technical Memo August 4, 2020 Page 9
Figure 3. Water Demand Forecasts Compared to Existing Supply Capacity
Summary The water demand forecast developed for the City of Villa Rica water system is based on historic water usage records, combined with adjustments to residential per capita rates to account for plumbing code efficiencies taking place over the planning period. Currently, the total water demand for the Villa Rica water system is comprised of approximately 60% residential, 28% commercial, 10% industrial, and 3% irrigation. For water use projections, industrial water demand is held at a consistent 10% of the total water demand until 2025, and then an additional industrial component of 2% is added to account for potential future industry. Irrigation water demand is held at a constant 3% of the total water demand throughout the entire water use projection. A reserve capacity is included in the forecasts, which is designed to allow the City to provide water service to new commercial customers or employment centers that may develop over the planning horizon. The reserve capacity begins in 2020 with 5% and increases to 15% by 2055. Non-revenue water estimates are accounted for in the historic data and in water use projections. The water demand forecast indicates that the City has an adequate water supply of drinking water for their current and future projected average daily water needs until 2025, at which time they will need to expand their own raw water supply or supplement their existing water source with purchased water.
0.00
0.50
1.00
1.50
2.00
2.50
3.00
3.50
Wat
er D
eman
ds (M
GD)
Year
Average Day Demand Peak Day Demand Existing Max Day Water Withdrawal
Action Item Amendment Proposal
TO: Executive Committee FROM: District Staff DATE: August 13, 2020 RE: Proposed 2020 Plan Amendments Due to COVID-19 and Changed Circumstances ________________________________________________________________________ At the District’s board meeting in May 2020, the question was raised whether there are any action items that no longer fit the present circumstances of increasingly tight budgets and stretched staff, especially given COVID-19. Based on this question, District staff reviewed the action items in the District’s 2017 Water Resources Management Plan (2017 Plan) and propose the following changes:
• WSWC-9: Pre-Rinse Spray Valve Replacement Program (See Exhibit 1) – The proposed plan amendment would sunset this action item based on new, mandatory federal high-efficiency standards, COVID-19 impacts on change-out program structures, and high natural change-out rates.
• WSWC-8: Commercial Water Use Assessments (See Exhibit 2) – Due to COVID-19 business impacts and public health considerations associated with in-person audits, the proposed plan amendment would suspend the requirement for local water providers to implement this action item except to provide education materials upon request. This action item would then be reevaluated as part of the 2022 plan update process.
• WSWC-6: Toilet Replacement Program (See Exhibit 3) – The proposed plan amendment would change this action item to require 1.1 gallon per flush (gpf) or less toilets instead of the current, less efficient 1.28 gallon per flush (gpf) toilets. This change would apply to both the single and multi-family programs. The District and local water providers would have until July 1, 2021 to finalize these changes. District staff is recommending a rebate amount of $75 per 1.1 gpf or less toilet. These changes would increase the efficiency of the toilets being rebated, reduce program costs, and decrease local and District staff time needed to administer the program. These changes are consistent with other nation-leading toilet rebate programs across the United States.
• Watershed-11: Macroinvertebrate Bioassessment (See Exhibit 4) – The proposed plan amendment would remove this action item from the 2017 Plan. Watershed-11 requires benthic macroinvertebrate and habitat monitoring of wadable streams at permanent representative stations. This action item is duplicative for communities who are subject to Georgia Environmental Protection Division’s (EPD) requirement for implementation of a Watershed Protection Plan (WPP), which includes benthic macroinvertebrate, fish, and habitat monitoring of wadable streams at permanent stations. For other
2
communities, the action item is duplicative in practice as described in the additional background information in Exhibit 4.
• Small Communities (See Exhibit 5) – The proposed plan amendment would change all action items to voluntary recommendations for small communities. District staff would continue to provide technical assistance to small communities upon request. Small communities for this amendment are those that meet at least one of the following conditions: (a) small water systems that depend primarily on groundwater and serve less than 3,300 people, (b) wastewater collection only systems that serve less than 3,300 people, and (c) local governments that don’t have a Municipal Separate Storm Sewer System (MS4) permit. This change reduces the administrative burdens faced by small communities, EPD staff, and District staff and has a de minimis impact on planning outcomes given these small communities consist of less than 1/3 of one percent of the District’s population.
District staff recommends that these proposed amendments be advanced through the next steps of the plan amendment process and that they be categorized as a major amendment and subject to a 30-day public comment period because they are regional in nature. Next steps will include presentation to the full Governing Board, presentation to the relevant Technical Coordinating Committees and the Basin Advisory Councils, and public notice and comment. The amendment will then be presented to the Executive Committee and full Governing Board in December 2020 for final consideration. These plan amendments would be effective Jan. 1, 2021, and District staff would work with EPD to update the audit spreadsheet.
3
Exhibit 1 Pre-Rinse Spray Valve Replacement Amendment
Description. This proposed plan amendment would sunset Action Item WSWC-9: Pre-Rinse Spray Valve Replacement Program based on new, mandatory federal high-efficiency standards, COVID-19 impacts on change-out program structures, and high natural change-out rates. At the time the 2017 Plan was being developed, the mandatory federal standard for Pre-Rinse Spray Valve (PRSV) efficiency was 1.6 gallon per minute (gpm) and WaterSense, which is a voluntary water efficiency program, labeled PRSVs that used 1.28 gpm or less. The PRSV action item was developed to facilitate replacement of older, inefficient PRSVs with high-efficiency WaterSense models. The following conditions have changed since the 2017 Pan was developed. First, in January 2019 WaterSense sunsetted its program for PRSVs. While some WaterSense labeled PRSVs were still available for a time after this date while sellers worked through their existing inventory, WaterSense-labeled PRSV are no longer readily available. Second, in January 2019, the Department of Energy’s nationwide, mandatory standard took effect requiring all classes of new PRSV meet or exceed the previous WaterSense standard. The effect of the new standard is that any time a PRSV is replaced at the end of its useful life, the new PRSV will be a high-efficiency model. The new standard is as follows:
Third, due to business impacts and public health considerations, PRSV replacement programs that involve in-person visits are no longer advisable. One common replacement program structure under this action item involved local water providers purchasing PRSVs in bulk and then offering them to restaurant owners, often through in-person visits. Additionally, many restaurants are closed, some permanently, and others are focusing on take-out orders to reduce COVID-19 exposure risks. Even after the business impacts and public health considerations of COVID-19 pass, it may not be worth promoting a PRSV replacement program given their very short useful lives and the resulting high rate of natural replacement. For example, California Energy Wise determined the natural turnover rate of 5 years for PRSVs based upon collected performance data from products on the California Energy Wise Qualifying Product List. Replacement programs make more sense when they meaningfully accelerate product replacement. Toilets are generally considered to have a useful life of between 30 and 50 years, and so accelerating the replacement of these products provides years of water savings before natural replacement would have otherwise occurred. The District provides technical assistance for this action item through bulk purchases, outreach efforts and education material distribution. Information about PRSV efficiency and water saving practices when using a PRSV will be incorporated into District education materials as appropriate, but bulk purchases and individual outreach efforts will cease. Proposed Amendment Language. This proposed amendment will be made by deleting the text of the action item and replacing it with the following text: “Based on new, mandatory high-efficiency standards, the action item on pre-rinse spray valve replacement programs will sunset effective January 1, 2021. No further action is required by local water providers regarding this action item.”
4
Exhibit 2 Commercial Water Use Assessments Amendment
Description. Due to COVID-19 business impacts and public health considerations associated with in-person audits, this proposed plan amendment would suspend Action Item WSWC-8: Commercial Water Use Assessments except to provide education materials upon request. This action item will be reevaluated as part of the 2022 plan update process once the impacts of COVID-19 on businesses are known. The immediate economic hardships facing businesses due to Covid-19 are likely to consume their attention for the foreseeable future and deplete any capital for mid- to long-term investments, like those in water efficiency. Additionally, many businesses are closed or are otherwise trying to limit the number of people on-site for public health reasons. If there is interest in increasing water efficiency from a local business, education materials will be provided to them by District staff. These materials will be self-guided in nature to continue to promote reduction in water use. Education materials include but are not limited to:
My Drop Counts Business Pledge. This is a program created by the District where businesses can pledge to conserve water through various Water Saver statuses ranging from Platinum to Bronze. Pledging requires employers and employees to actively discuss the significance of water efficiency within the workplace, perform water use assessments, inspect for leaks and increase the efficiency of fixtures where appropriate. There are pledges for both indoor and outdoor efficiency steps of action.
WaterSense Simple Water Assessment Checklist for Commercial and Institutional Facilities. The EPA WaterSense program offers a list of water efficient practices and projects that can be evaluated, implemented, and completed by the business. There is an accompanying “WaterSense at Work: Best Management Practices for Commercial and Institutional Facilities” handbook detailing information and calculations to determine potential water savings.
Water Project Screening Tool. The Federal Office of Energy Efficiency and Renewable Energy provides a water project screening tool created by the Federal Energy Management Program. Based upon data input by the user, the tool provides quantitative values for potential water savings.
EDF-GEMI Water Efficiency Toolkit. This toolkit provides three tools to evaluate a business’s water efficiency: a water scorecard, water efficiency calculator and a cycles of concentration estimator. Together these tools help to determine the property’s current water efficiency, estimated water and financial savings and assessments on cooling tower efficiency.
These resources will be compiled and made readily available in a digital format for easy accessibility to businesses. Any later additional resources and information can also be added. In this way, the information becomes a living document that can continually reflect the latest standards in efficiency to heighten awareness and integration with local businesses in the region. Proposed Amendment Language. The following text will be added in red under responsible party for WSWC-8: “Effective January 1, 2021: Due to COVID-19 business impacts and public health considerations, this action item has been suspended and no action is required by the responsible party. Education materials will be available by the District upon request by commercial water users.”
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Exhibit 3 Toilet Replacement Program Amendment
Description. This amendment would update Action Item WSWC-6: Toilet Replacement Program to require 1.1 gallon per flush (gpf) or less toilets. This would apply to both the single and multi-family programs. The District and local water providers would have until July 1, 2021 to finalize these changes. District staff is recommending a rebate amount of $75 per 1.1 gpf or less toilet, to be standardized across the District and local water providers. Additionally, as a matter of customer service, rebates of 1.28 gpf may still be allowed when a customer in good faith purchases a dual-flush toilet with one flush at 1.1 gpf or less or uses an outdated paper rebate application form provided by a retailer. The District gathered in store retail product availability at Home Depot and Lowe’s in 2019 and 2020. 7 out of 8 stores stocked at least one toilet model using 1.1 gpf or less. The average customer satisfaction with 1.28 gpf versus 1.1 gpf toilets was 4.4 out of 5.0 and 4.9 out of 5.0, respectively. In addition to toilets stocked in stores, there are more than 500 models available in the marketplace based on a review of the MaP PREMIUM list for residential and light commercial toilets. Online market research performed by District staff in 2020 confirm current availability of these models. Currently, some local water providers run their own toilet rebate programs. The District manages a regional single-family toilet rebate program on behalf of 25 local water providers for an administrative fee of $10 per toilet. For the District-managed single-family rebate program, from June 2019 to May 2020, the District processed an average of 130 rebates per month for 1.28 gpf toilets at a $50 rebate value, and 11 toilets per month using 1.1 gpf or less at a $100 rebate value. The average total monthly amount for rebates and fees is $9,010. Based on experience and review of other rebate programs across the United States, the District estimates that rebating only 1.1 gpf or less toilets will result in an increase in the number of 1.1 gpf toilets being rebated somewhere between two and four times the current average the first year or two following the change. At four times the number of 1.1 gpf or less toilets being rebated at $75 each plus a $10 administrative fee, the average total monthly amount for rebates and fees would be $3,740. Under the revised program, local water providers in the District program would collectively see an estimated average annual reduction in program costs of $63,240, plus whatever savings would be achieved for those managing their own programs. This change would also reduce administration time at both the District and local levels. To date, every application the District has received for its multi-family rebate program has included 1.1 gpf toilets or less. While eliminating the 1.28 gpf option in the multi-family program will not result in cost savings, it will bring the District’s program in line with other nation-leading programs. Proposed Amendment Language. The existing language of WSWC-6 would be revised as shown on the following page:
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WSWC-6: Toilet Replacement Program Intent
To reduce indoor water use and speed the conversion of older, inefficient toilets toward WaterSense labeled ultra-high-efficiency toilets in single- and multi-family homes.
Points of Integration
This measure should result in decreased water demands, as well as decreased wastewater flows.
Responsible Party
Local Water Provider
In Coordination With
Local Government Local Wastewater Provider
Action Item: Implement a program to replace older, inefficient toilets with WaterSense labeled ultra-high-efficiency toilets using 1.1 gpf or less (WaterSense UHET) in single- and multi-family homes. WaterSense labeled toilets using 1.28 gpf will no longer be eligible for rebates after July 1, 2021.
Sub-Tasks: Each local water provider shall: 1. Establish a program to replace 3.5 gpf or greater toilets in single- and multi-family homes constructed
prior to 1994 with WaterSense UHETs high-efficiency WaterSense labeled toilets.
2. Provide information on opportunities to recycle any toilet being discarded pursuant to the toilet replacement program by linking to the Metro Water District website or other local resources.
Description: Single- and multi-family homes built prior to 1994 may contain inefficient toilets. While new toilets meet high efficiency standards, the replacement of older, inefficient toilets is needed to address existing stock and reduce indoor water use.
Implementation Guidance: Before the 1950s, new toilets typically used 7 gpf. By the end of the 1960s, new toilets typically used 5.5 gpf; in the 1980s, new toilets typically used 3.5 gpf. The federal Energy Policy Act of 1992 required all new toilets use no more than 1.6 gpf by 1994. In 2010 the Georgia Water Stewardship Act required that local governments adopt or amend local ordinances to require, among other things, that all new construction, on or after July 1, 2012, use WaterSense labeled toilets. WaterSense is a voluntary program of the EPA designed to identify and promote water efficient products and practices. WaterSense labeled toilets are independently certified to meet rigorous criteria for both performance and efficiency. Today, WaterSense UHETs are increasingly available with efficiency levels of 1.1 gpf or less.
This Action Item calls for a program to replace toilets in single and multifamily homes constructed prior to 1994 with WaterSense UHETs.labeled toilets. As of the date of this Plan, the WaterSense efficiency criteria is 1.28 gpf or less for toilets, and in the future, the WaterSense label may become more stringent. If a more stringent criterion is adopted, it will apply as of the date of its adoption for the purposes of this Plan.
The toilet replacement program must specifically address toilet replacement rather than provide toilet retrofit devices. Examples of acceptable toilet replacement programs include the following:
• Rebate incentive program: Customer receives a water bill credit, cash or voucher to offset the cost of a new WaterSense UHET labeled toilet to be installed in a pre-1994 single- or multi-family home. Rebates shall be $75.
• Direct install program: Customer exchanges a toilet from pre-1994 single- or multi-family homes for a WaterSense UHETlabeled toilet with discounted installation through the local water provider.
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• Other: Local water providers may create their own programs as long as the program actually results in the replacement of toilets in pre-1994 single- and multi-family homes with WaterSense UHETs. These programs may take a variety of forms, including but not limited to on-bill financing programs for toilet replacements and programs requiring that toilets using 3.5 gpf or more be replaced as a condition of a customer establishing water service.
If a local water provider chooses to have a single replacement program covering both single and multi-family homes, funds may be made available on a first come, first served basis. As a matter of customer service, rebates of 1.28 gpf may still be allowed as a hardship exception when a customer in good faith purchases a dual-flush toilet with one flush at 1.1 gpf or less or uses an outdated paper rebate application form provided by a retailer. Due to the high value of rebate programs for multi-family homes, it is recommended that the local water provider include an inspection element in any multi-family rebate program to prevent possible fraud. This can be done through a physical inspection or by reviewing billing data post-installation. The local water provider should provide information on available toilet recycling opportunities. There are recycling facilities in the region that will recycle crushed porcelain for various uses, such as a concrete aggregate or bathroom tile. Many homeowners may not be aware of recycling options when replacing a toilet.
Considerations for Enhanced Implementation: The optional considerations for enhanced implementation include the following: • Add an additional requirement that program participants provide documentation or other proof that
the replaced toilet uses 3.5 gpf or more, such as requiring a section on the rebate application form for the customer to record the gallons per flush of the old toilet or including a customer self-certification.
• Encourage customers to purchase WaterSense labeled ultra-high-efficiency toilets that use 1.1 gpf or less through a tiered rebate incentive with a higher rebate tier for toilets meeting these standards.
• Limit rebates to only WaterSense labeled ultra-high-efficiency toilets that use 1.1 gpf and discontinue rebates on 1.28 gpf toilets.
• Low-income and disadvantaged customers often live in pre-1994 single- and multi-family homes and spend a greater percentage of their income on utility bills. These customers may experience financial difficulties participating in a rebate incentive program if they cannot afford to purchase the new plumbing fixture before the rebate money is received. A voucher or direct install program for customers with a lower household income would encourage indoor water efficiency in in pre-1994 single- and multi-family homes. As an example, the City of Atlanta’s Care and Conserve program provides payment assistance to qualified customers.
• Local water providers may also consider placing toilet recycling containers at other local government buildings. The City of Atlanta provides free toilet recycling to its residential water customers at the Center for Hard to Recycle Materials. Gwinnett County Water Resources offers free toilet recycling to its residential customers by providing a recycling container for old toilets at its building. Gwinnett County Water Resources covers the cost of transporting the container to a local recycler. This free service is promoted to customers participating in the toilet replacement program and has kept hundreds of tons of porcelain from the landfill.
• Require recycling for all toilets replaced through the multi-family toilet replacement program. Some local water providers require the customer to agree to transport the used porcelain toilets to an
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approved recycler within the Metro Water District area. The customer must provide documentation from the recycler that the toilets were disposed properly before the rebate credit will be issued to the account.
Opportunities for Technical Assistance: The Metro Water District’s Technical Assistance Program may provide support for implementation of this Action Item through the following types of activities:
• Administering a regional rebate program for single-family homes
• Creating and administering a regional rebate program for multi-family homes
• Offering a regional program for low-income and disadvantaged customers using grant funding
• Developing a regional list of toilet recycling facilities
Resources:
• EPA, WaterSense Toilets, information page, https://www3.epa.gov/watersense/products/toilets.html
• Cobb County, toilet recycling information (see Item No. 16),
https://cobbcounty.org/index.php?option=com_content&view=article&id=3445&Itemid=1544
• MaP Testing Premium Ultra-High-Efficiency Toilet page, http://www.map-testing.com/content/info/menu/map-premium.html
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Exhibit 4 Water Quality Monitoring Plan Amendment
Description. The proposed plan amendment would remove Watershed Action Item 11 – Macroinvertebrate Bioassessment (WA-11). WA11 requires benthic macroinvertebrate and habitat monitoring of wadable streams at permanent representative stations. This action item is duplicative for communities who are subject to Georgia Environmental Protection Division’s (EPD) requirement for implementation of a Watershed Protection Plan (WPP), which includes benthic macroinvertebrate, fish, and habitat monitoring of wadable streams at permanent stations. For other communities, the action item is duplicative in practice as further discussed below. EPD requires WPPs to be developed by any permittee holding a permit for a wastewater treatment facility designed for one million gallons per day or greater. WA-11 allows local jurisdictions with WPPs to submit the WPP bioassessment data to fulfill the action item. For local jurisdictions without a WPP, habitat and biological monitoring must be conducted at permanent representative stations established using 2017 Plan Table 5-4: Minimum Number of Permanent Stations for Long-Term Trend Monitoring, or they may establish an agreement with another local jurisdiction that will conduct monitoring on their behalf. A macroinvertebrate bioassessment can be costly for local jurisdictions and, unlike water quality monitoring, is rarely conducted by internal staff. Scientists that conduct monitoring are required to have a Collecting Permit issued by the Wildlife Resources Division. It is common for scientists that conduct the monitoring to preserve collected specimens and outsource their taxonomic classification. Additional training and equipment are required to identify macroinvertebrates to a species level, which includes close examination of the specimen features with a hand lens or microscope. The most common way local jurisdictions meet requirements of WA-11 is to submit WPP bioassessment data. The second most common way is to establish an agreement with another local jurisdiction, often one with a WPP, to conduct monitoring on their behalf. In that way, WA11 implementation is generating limited new data to measure watershed health. By contrast, WA-11 does generate administrative burden. For local jurisdictions with a WPP, data must be submitted for both WPP and 2017 Plan compliance. For local jurisdictions that have established an agreement for macroinvertebrate bioassessments, data sharing and coordination must be formalized through a MOA or MOU and may include legal review to establish timeframes, compensation (if any), and other parameters for cooperation between jurisdictions. Removing WA-11 will allow local jurisdictions to continue collecting and submitting WPP bioassessment data without impacting EPD data collection or analysis. Additionally, removing the administrative burden of duplicative submittals and monitoring agreements, will allow limited funding and staff time to be focused on issues of local importance. Proposed Amendment Language. This proposed amendment will be made by deleting the text of the action item and replacing it with the following text: “This action item will sunset effective January 1, 2021 because it was duplicative with EPD requirements and/or otherwise duplicative in practice. No further action is required by local entities regarding this action item.”
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Exhibit 5 Small Communities Amendment
Description. The proposed plan amendment would change all action items to voluntary recommendations for small communities defined as: (a) small water systems that depend primarily on groundwater and serve less than 3,300 people, (b) wastewater collection only systems that serve less than 3,300 people, and (c) local governments that don’t have a Municipal Separate Storm Sewer System (MS4) permit. Whether a community is a small community will be reviewed again with each future plan update. District staff would continue to provide technical assistance to small communities on action item voluntary recommendations upon request. The scope of small communities’ involvement in water, wastewater, and stormwater management is very limited. Small communities collectively make up less than 0.3% of the total population and 0.7% of the land area in the District. Nonetheless, small community staff, District staff, and EPD staff spend significant time and resources implementing action items, providing technical assistance, and auditing small communities. Furthermore, it is often unclear how and to what extent action items are relevant given the limited scope of small communities’ operations. At the same time, community budgets and staff are already stretched in their effort to meet critical health, safety, and environmental needs and maintain their physical infrastructure. This situation is more challenging today given COVID-19 and its direct and indirect impacts on the staffing, budgets, and operations of communities. There is precedent in state and federal regulatory programs to tailor requirements based on size for these very same reasons. The 3,300-person threshold is used in many drinking water-related regulations and the MS4 permitting program uses a threshold of “urbanized area.” Changing action items to voluntary recommendations will allow District staff and EPD staff to focus on the areas of greatest regional need for technical assistance and plan compliance auditing. Proposed Amendment Language. Insert the language on the following page immediately before Section 5.1 on page 5-2 in the June 2017 Water Resources Management Plan:
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“For the small communities listed in the table below, the action items in this plan are voluntary recommendations. The District encourages these small communities to take those actions from the plan that are most relevant to local areas of need. The District’s Technical Assistance Program is available to all small communities. Small communities will not be audited by EPD.
Small Local Governments Service(s) Provided 2014 Population
Clermont (Hall County) SW 915 Gillsville (Hall County) SW 246
Lula (Hall County) W, WW, SW 2,867 Haralson (Coweta County) SW 173 Moreland (Coweta County) SW 418 Sharpsburg (Coweta County) SW 351 Turin (Coweta County) W, SW 336 Kingston (Bartow County) W, SW 651 Taylorsville (Bartow County) SW 213 White (Bartow County) W, SW 674 Ball Ground (Cherokee County) W, WW, SW 1,658 Nelson (Cherokee County) SW 1,342 Waleska (Cherokee County) W, SW 871 Brooks (Fayette County) W, WW, SW 540 Woolsey (Fayette County) SW 2,086 Rest Haven (Gwinnett County) SW 62 Braswell (Paulding County) SW 379 Total 13,782 % of District 0.29%
This list was prepared based on the following definition of small communities: (a) local water providers that depend primarily on groundwater and serve less than 3,300 people, (b) wastewater providers that are collection only systems that serve less than 3,300 people, and (c) local governments that don’t have a Municipal Separate Storm Sewer System (MS4) permit. In the column titled “Service(s) Provided,” the letters correspond with the following responsible parties from the action items: W stands for local water provider, WW stands for local wastewater provider, and SW stands for local governments. This list is based on 2014 population numbers, which is the baseline for this plan. The small communities list will be updated during the next plan update based on the baseline population numbers and MS4 permits that have been issued at that time.”
2021 Budget Revision
MEMORANDUM Date: August 26, 2020 To: Executive Committee From: Dr. Mark Berry, Treasurer RE: Revision to the District’s 2021 Budget ________________________________________________________________________ On June 8, 2020, the Governing Board approved the 2021 District Budget with a dues rate of $0.30 per capita to help fund the 5-year update to the Water Resource Management Plan. The budget assumed the State of Georgia would provide $172,000 in its FY21 appropriations to the District. Since the District’s budget was approved, the State finalized its FY21 budget providing the District with $750,000 ($200,000 for annual administration funding plus an additional $550,000 for Plan update expenses) in state appropriations. This additional funding will allow the Governing Board to consider modification of the prior approved dues rate before invoices are mailed, thereby lowering the burden on local dues payers. The proposed District 2021 Budget revision is attached and includes the following key changes:
- A reduction to the District Dues payments from $0.30 to $0.25 per capita. Invoices to be mailed following August 26, 2020 board budget action.
- State Funding (Appropriations) increased from $172,000 to $750,000 to reflect the final State FY21 Budget
- Contracts line item increased by $25,000 to fund full scope item for the resiliency task in the Plan Update contract that was previously removed
- Additional $100,000 in Task Order Support for the Plan Update contract to address potential additional services such as resiliency. This additional contract amount will be recognized in the 2022 Contracts line item.
- Public Awareness/Education restored to prior level of $100,000 The District’s Finance Committee held a conference call meeting on August 4, 2020 to review the proposed budget revision for 2021. The Finance Committee recommends the proposed revision for approval.
2021 BudgetMetropolitan North Georgia Water Planning District
PROPOSED August 26, 2020
2021 2021 2022Approved
June 8, 2020Proposed
August 26, 2020CONCEPTUAL
Per Capita Dues Rate $ 0.300 $ 0.250 $ 0.250
Beginning Fund Balance (Estimated) 513,330 513,330 782,413
RevenuesState Funding (Appropriations) 172,000 750,000 250,000 State Funding (GEFA) - - - Source Water Assessment Plan Grant (GEFA/DNR) - - - Local Dues (2010 Census at per capita rate) 1,449,823 1,208,186 1,208,186 Interest Income 1,000 1,000 1,000 Misc. Fees 45,000 45,000 45,000
Total Revenues 1,667,823 2,004,186 1,504,186
Expenses by TypeChairman's Allowance 3,000 3,000 3,000 District Planning Function
Salaries 514,666 514,666 535,253 Fringe Benefits 303,653 303,653 315,799 Overhead 338,784 338,784 352,335 Contracts 365,000 390,000 365,000
Septic Study - Wet Weather 200,000 Miscellaneous Operating 85,000 85,000 75,000 Public Awareness / Education 75,000 100,000 100,000
Total Expenses 1,685,103 1,735,103 1,946,387
2022 Plan Update Reserve 196,050 482,413 - Projected Reserve Fund Balance 300,000 300,000 300,000
Projected Ending Fund Balance 496,050 782,413 340,211
NOTES
Misc. Operating:
1. The District received $200,000 for District Administration plus $550,000 for District Plan Update from appropriations for State FY2021.
2. The District will strive to maintain a minimum fund balance of $300,000 for operating contingencies.
Contracts: 2022 Water Resource Management Plan Update, Drought management technical assistance, governmental affairs and other contracts
This category includes operating supplies, publications, printing and photocopying, meeting expenses, postage, contractual photocopying, meeting expenses, postage, contractual, operating services such as audit, seminar trainers and other misc.
2022 Water Resource Management Plan Consultant
Contract
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MNGWPD Contract No.
CONTRACT FOR PROFESSIONAL SERVICES THIS AGREEMENT, entered into as of this day of , 2020 by and between Jacobs Engineering Group, of Atlanta, Georgia (hereinafter referred to as the "Consultant") and the Metropolitan North Georgia Water Planning District, (hereinafter referred to as "MNGWPD" or "the District".
W I T N E S E T H T H A T
WHEREAS, MNGWPD, pursuant to O.C.G.A. § 12-5-570 et.seq, is obligated to develop regional and watershed-specific plans; and
WHEREAS, MNGWPD desires to engage the Consultant to render certain technical or professional services hereinafter described in connection with an undertaking or project (hereinafter referred to as the "Project") which is to be wholly or partially financed by funds from the State of Georgia, the United States Government, or participating Local Governments (hereinafter, along with the appropriate auditing agency of the entity providing such funds, referred to as the "Concerned Funding Agency or Agencies"); and
WHEREAS, the Consultant desires to render such services in connection with the Project;
NOW THEREFORE, in consideration of the premises, and the mutual covenants and agreements hereinafter contained, the parties hereto agree as follows:
1. Employment of the Consultant. MNGWPD hereby agrees to engage the Consultant
and the Consultant hereby agrees to perform the services hereinafter set forth in accordance with the terms and conditions contained herein.
2. Time of Performance. The services of the Consultant are to commence no later than
fifteen (15) days after the execution of this contract and shall be undertaken and pursued in such sequence as to assure their expeditious completion and as may be required in Attachment "A". All services required hereunder shall be completed by or before March 31, 2023.
3. Compensation and Method of Payment. The Consultant shall be compensated for the
work and services to be performed under this contract as set forth in Attachment "B" which is attached hereto and made a part hereof. In no event, however, will the total compensation and reimbursement, if any, to be paid the Consultant under this contract exceed the amount as further described in Attachment "B" of this contract.
4. Scope of Services. The Consultant shall do, perform and carry out in a satisfactory
and proper manner, with the skill and diligence normally employed by Consultants performing similar work and services, the work and services described in Attachment "A", which is attached hereto and made a part hereof. The Consultant shall ensure adequate review, coordination and
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approval of the work with MNGWPD's Chief Executive Officer (CEO) or his authorized agent (as used herein the CEO's "authorized agent" shall mean that person designated by MNGWPD's CEO in Paragraph 27 of this contract).
5. Progress Payments. Unless otherwise provided in Attachment "B", the Consultant
shall be entitled to receive progress payments on the following basis: As of the last day of each calendar month during the existence of this contract, the Consultant shall submit to MNGWPD an invoice for payment based on the percentage of completion of the Project through the invoice period. Subject to MNGWPD's right to verify the accuracy of the invoice and the satisfactory performance of the work evidenced thereby, MNGWPD will make payments to the Consultant as the work progresses but not more often than once a month. Invoices must cover a period ending with the end of a month and must be received within fifteen (15) days following the end of the invoice period. The Consultant will be paid an amount which bears the same ratio to the total compensation to be paid to the Consultant under this contract as the work and services actually performed as of the end of the invoice period bear to the total work and services to be performed by the Consultant under this contract, less all previous progress payments made pursuant hereto, and less an established retainage. Upon completion and acceptance by MNGWPD of the work, including the receipt of any final written submission of the Consultant, MNGWPD shall pay the Consultant a sum equal to one hundred per cent (100%) of the compensation to be paid under this contract, less the total of all previous payments made. Such payment shall be made no later than thirty days after MNGWPD's acceptance of the Consultant's invoice and MNGWPD's receipt of such funds from the Concerned Funding Agency.
6. Consultant's Personnel. The Consultant represents that he has, or will secure at his
own expense, all personnel required in performing the services under this contract. Such personnel shall not be employees of MNGWPD, nor shall such personnel have been employees of MNGWPD during any time within the twelve-month period immediately prior to the date of this contract, except with the express prior written consent of MNGWPD's CEO or his authorized agent. Further, the Consultant agrees that no such personnel shall be involved in any way with the performance of this contract, without the express prior written approval of MNGWPD's CEO or his authorized agent.
7. Approval of Subcontracts. None of the work or services to be performed under this
contract by the Consultant shall be subcontracted without the prior written approval of MNGWPD's CEO or his authorized agent. If such subcontracting is authorized as herein provided, all subcontract documents shall be submitted to MNGWPD's CEO or his authorized agent, for his review and approval prior to the execution of such subcontract. Further, if requested by MNGWPD's CEO or his authorized agent, the Consultant shall provide such documentation as MNGWPD shall require, regarding the method the Consultant used in selecting its subcontractor. The Consultant acknowledges that if the work or services to be performed under this contract is financed solely or partially through Federal funds, the selection of subcontractors is governed by regulations requiring competition between potential subcontractors or adequate justification for sole source selection. The Consultant agrees to abide by such regulations in its selection procedure.
8. Review and Coordination. To ensure adequate review and evaluation of the work, and proper coordination among interested parties, MNGWPD shall be kept fully informed concerning the progress of the work and services to be performed hereunder. MNGWPD may require the
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Consultant to meet with designated officials of MNGWPD and the Concerned Funding Agency from time to time to review the work. Reasonable prior notice of such review meeting shall be given the Consultant.
9. Reports. The Consultant shall furnish MNGWPD with a monthly narrative progress
report, in such form as may be specified by MNGWPD's CEO or his authorized agent, outlining the work accomplished by the Consultant during the month of such report and the current status of the Project, including the percentage of the work which has been completed as of the end of the month of such report. Such report shall be furnished within fifteen (15) days of the end of the month of such report.
10. Inspections. Authorized representatives of MNGWPD and the Concerned Funding
Agency may at all reasonable times review and inspect the Project activities and data collected pursuant to this contract. All reports, drawings, studies, specifications, estimates, maps and computations prepared by or for the Consultant shall be made available to authorized representatives of MNGWPD and the Concerned Funding Agency for inspection and review at all reasonable times in the Consultant's office where data is normally accumulated. Approval and acceptance of such material shall not relieve the Consultant of his professional obligation to correct, at his expense, any errors found in the work.
11. Maintenance of Cost Records. The Consultant shall maintain all books, documents,
papers, accounting records and other evidence pertaining to costs incurred on the Project and shall make such material available at all reasonable times during the period of the contract, and for three years from the date of final payment under the contract, for inspection by MNGWPD, the Concerned Funding Agency, and if the work and services to be performed under this contract is wholly or partially funded with Federal funds, the Comptroller General of the United States, or any other party as may be directed by MNGWPD. Notwithstanding this Section 11 or any other provisions of this contract and pursuant to the Georgia Open Records Act, O.C.G.A. § 50- 18-70 et.seq, all records received or maintained by Consultant or any other private entity in the performance of work and services under this contract shall be subject to disclosure to the same extent that such records would be subject to disclosure if received or maintained by MNGWPD or any other agency, public agency, or public office. The Consultant shall include the provisions of this paragraph in any subcontract executed in connection with this Project.
12. Compliance with Requirements of the Concerned Funding Agency. The Consultant
shall be bound by the applicable terms and conditions of the Grant Contract between MNGWPD and the Concerned Funding Agency, which said Grant Contract is on file in the offices of MNGWPD and is hereby made a part of this Agreement as fully as if the same were attached hereto.
13. Data to be Furnished Consultant. All information, data, reports, records and maps
which are existing, readily available and reasonably necessary, as determined by MNGWPD's CEO or his authorized agent, for the performance by the Consultant of the work and services required by this contract shall be furnished to the Consultant without charge by MNGWPD. MNGWPD, its agents and employees, shall fully cooperate with the Consultant in the performance of the Consultant's duties under this contract.
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14. Rights in Documents Materials and Data Produced. Consultant agrees that all reports, drawings, studies, specifications, estimates, maps, computations and other data prepared by or for it under the terms of this contract shall be delivered to, become and remain the property of MNGWPD upon termination or completion of the work. MNGWPD shall have the right to use same without restriction or limitation and without compensation to the Consultant other than that provided for in this contract. For the purposes of this contract, "data" includes writings, sound recordings, or other graphic representations and works of a similar nature. No materials or data produced in whole or in part under this contract shall be the subject of an application for copyright by or on behalf of the Consultant or its subcontractors. If the work to be performed under this contract is financed wholly or partially by Federal funds, the Consultant acknowledges that matters regarding the rights to inventions and materials generated by or arising out of this contract may be subject to certain regulations issued by the Concerned Funding Agency. Information regarding these relevant regulations may be obtained upon written request to MNGWPD's CEO or his authorized agent. If this contract provides for the development of systems analysis products, models, electronic data processing systems, software and related services, the methods, material, logic and systems developed under this contract shall be the property of Consultant. However, MNGWPD, and the Concerned Funding Agencies shall retain the right, in perpetuity, to use, and to authorize others within the State of Georgia to use the systems analysis products, models, electronic data processing systems, software and related services, the methods, material, logic and systems without restriction or limitation and without compensation to the Consultant other that that provided for in this contract. The foregoing notwithstanding, any review or use of the systems analysis products, models, electronic data processing systems, software and related services, the methods, material, logic and systems by third parties or for purposes other than outlined herein shall be at the sole risk of such party and without fault or liability to Consultant.
15. Identification of Documents. Unless otherwise provided in Attachment "A", all
reports, maps and other documents completed as a part of this contract shall bear on the title page of such report, map or document, the following legend: "Prepared by (insert name of Consultant) under Contract with the Metropolitan North Georgia Water Planning District. The preparation of this (insert either report, map or document, as appropriate) was financed in part by funds provided by (insert name of the Concerned Funding Agency and an identification of the grant program)." The date (month and year) in which the document was prepared shall also be shown.
16. Publication and Publicity. Articles, papers, bulletins, reports or other material reporting
the plans, progress, analysis or results and findings of the work conducted under this contract shall not be presented publicly or published without prior approval of MNGWPD's CEO or his authorized agent. All such reports, information, data, etc., shall be kept confidential by the Consultant and shall not be made available to any individual or organization by the Consultant, until MNGWPD's CEO or his authorized agent authorizes the release of same in writing. All articles, paper, bulletins, reports or other material reporting plans, progress, analysis or results and findings of the work conducted under this contract are subject to Georgia’s Open Records Act, O.C.G.A. § 50-18-70 et. seq. Consultant shall notify MNGWPD, within twelve (12) hours of the receipt of any and all requests to review any such articles, paper, bulletins, reports or other material.
17. Interest of Consultant. The Consultant covenants that neither the Consultant, nor anyone controlled by the Consultant, controlling the Consultant, or under common control with the Consultant, nor their agents, employees or subcontractors, presently has an interest, nor shall
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acquire an interest, direct or indirect, which would conflict in any manner or degree with the performance of its service hereunder, or which would prevent or tend to prevent, the satisfactory performance of the Consultant's service hereunder in an impartial and unbiased manner. The Consultant further covenants that in the performance of this contract no person having any such interest shall be employed by the Consultant as an agent, subcontractor or otherwise. If the Consultant contemplates taking some action which may constitute a violation of this paragraph 17, the Consultant shall request in writing the advice of MNGWPD's CEO or his authorized agent, and if MNGWPD's CEO or his authorized agent shall notify the Consultant in writing that the Consultant's contemplated action will not constitute a violation hereof, then the Consultant shall be authorized to take such action without being in violation of this paragraph.
18. Interest of Member of MNGWPD and Others. No officer, member or employee of
MNGWPD, and no public official of any local government which is affected in any way by the Project, who exercises any function or responsibilities in the review or approval of the Project or any component part thereof, shall participate in any decision relating to this contract which affects his personal interest or the interest of any corporation, partnership or association in which he is, directly or indirectly, interested; nor shall any such officer, member or employee of MNGWPD, or public official of any local government affected by the Project, have any interest, direct or indirect, in this contract or the proceeds arising therefrom.
19. Official Not to Benefit. No member of or delegate to the Congress of the United States
of America, resident Commissioner or employee of the United States Government shall be admitted to any share or part of this contract or to any benefit to arise here from.
20. Nondiscrimination.
(A) The Consultant will not discriminate against any qualified employee, applicant for employment or subcontractor because of age, handicap, religion, creed or belief, political affiliation, race, color, sex or national origin. The Consultant shall take affirmative action to ensure that qualified applicants are employed and qualified subcontractors are selected, and that qualified employees are treated during employment, without regard to their age, handicap, religion, creed or belief, political affiliation, race, color, sex or national origin. Such action shall include, but not be limited to the following: employment, upgrading, demotions, or transfers; recruitment or recruitment advertising; layoffs or terminations; rates of pay or other forms of compensation; selection for training including apprenticeship; and participation in recreational and educational activities. If the Consultant has fifty or more employees and if the total compensation and reimbursement to be paid to the Consultant as specified in paragraph 3 of this contract is Fifty Thousand Dollars ($50,000) or more, the Consultant certifies that: (1) It has developed a written Affirmative Action Program (AAP) which includes: (a) an analysis of the Consultant's work force showing by job category the extent to which minorities and females are being underutilized, and (b) where minorities and females are being underutilized, realistic goals and timetables in each job category for correcting the underutilization; and (2) It presently has such a plan in effect and such plan will remain in effect at least until the Project completion date specified in paragraph 2 of the contract. The Consultant agrees to post in a conspicuous place available to employees and applicants for employment, notices to be provided setting forth the provisions of this nondiscrimination clause. The Consultant will in all solicitations or advertisements for subcontractors or employees placed by or on behalf of the Consultant, state
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that all qualified applications will receive consideration for employment without regard to age, handicap, religion, creed or belief, political affiliation, race, color, sex or national origin. The Consultant will cause the foregoing provisions to be inserted in all subcontracts for any work covered by this contract so that such provisions will be binding upon each subcontractor provided that the foregoing provisions shall not apply to subcontracts for less than $10,000.00.
(B) The Consultant shall keep such records and submit such reports concerning the
racial and ethnic origin of employees and applicants for employment as MNGWPD or the Concerned Funding Agency may require.
(C) The Consultant agrees to comply with such rules, regulations or guidelines as
MNGWPD or the Concerned Funding Agency may issue to implement the requirements of this paragraph 20.
21. Changes. MNGWPD may require changes in the work and services that the Consultant
is to perform hereunder. Such changes, including any increase or decrease in the amount of the Consultant's compensation which are mutually agreed upon by and between MNGWPD and the Consultant, shall be incorporated in written amendments to this contract.
22. Assignability. The Consultant shall not assign, sublet or transfer all or any portion of
its interest in this Agreement without the prior written approval of MNGWPD's CEO or his authorized agent.
23. Indemnification. The Consultant shall hold harmless and indemnify MNGWPD, its
officers, directors, and employees from and against losses, reasonable attorney’s fees and costs, that may be based on any injury to persons or property caused to the proportionate extent by the negligent performance of services under this agreement by the consultant or any person employed by the consultant. Consultant’s liability to MNGWPD for all the aforesaid matters is limited to proceeds recovered from insurance and within the coverage limits specified in article 24 below.
24. Insurance. Consultant shall, as a minimum, place and maintain with responsible
insurance carriers the following insurance. Consultant shall deliver to MNGWPD, upon request, certificates of such insurance which shall provide written notice to be given to MNGWPD in the event of cancellation, in accordance with standard ACORD Form wording. Consultant shall require all subcontractors to maintain adequate insurance coverage.
A. Workers’ Compensation and Employer’s Liability Insurance: 1. Workers’ Compensation in compliance with applicable state and federal laws.
B. Liability Insurance ($100,000.00 for injuries including death to any one person
and $300,000.00 per occurrence) including: 1. Professional Liability; 2. Blanket contractual; 3. Broad Form Property Damage ($50,000.00 per occurrence with
aggregate limit of $1,000,000.00) 4. Completed Operations;
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5. Independent Contractor’s Liability 6. Valuable Papers.
C. Automobile Liability Insurance including owned, hired, and non-owned
automobiles, Bodily Injury and Property Damage to a combined single limit of $1,000,000 each occurrence.
25. Termination of the Contract for Cause. If the Consultant, due to its action or failure to
act, shall fail to fulfill in a timely and proper manner his obligations under this contract, or if the Consultant has or shall violate any of the covenants, agreements, representations or stipulations of this contract, MNGWPD shall thereupon have the right to terminate this contract by giving written notice to the Consultant of such termination and specifying the effective date thereof, at least five (5) days before the effective date of such termination. In such event, all finished or unfinished documents and other materials collected or produced under this contract (as more fully described in paragraph 14 hereof) shall, at the option of MNGWPD, become its property and the Consultant shall be entitled to receive just and equitable compensation for any satisfactory work completed on such documents or materials. Notwithstanding the foregoing, the Consultant shall not be relieved of liability to MNGWPD for damages sustained by MNGWPD by virtue of any breach of this contract by the Consultant, and MNGWPD may withhold any payment to the Consultant for the purpose of set-off for damages caused by the Consultant's breach, until such time as the exact amount of damages to MNGWPD from the Consultant is determined.
26. Termination for Convenience. MNGWPD may terminate this contract at any time by
giving written notice to the Consultant of such termination and specifying the effective date thereof, at least fifteen (15) days before the effective date of such termination. In that event, all finished or unfinished documents and other materials produced or collected under this contract (as more fully described in paragraph 14 above) shall, at the option of MNGWPD, become its property. If this contract is terminated by MNGWPD as provided in this paragraph 26, the Consultant will be paid either (a) an amount which bears the same ratio to the total compensation to be paid to the Consultant under this contract as the services actually performed prior to the termination of this contract bear to the total services to be performed by the Consultant under this contract, less payments of compensation previously made, provided, however, that if less than sixty percent (60%) of the services covered by this contract have been performed by the effective date of such termination, the Consultant shall be reimbursed (in addition to the foregoing payment) for that portion of the actual out of pocket expenses, plus subcontract/purchase order termination expenses due to an unaffiliated company, if any (not otherwise reimbursed under this contract) incurred by the Consultant during the contract period, which are directly attributable to the uncompleted portion of the services covered by this contract; or if payment under this contract is on a cost reimbursement basis, (b) the actual expenses incurred by the Consultant prior to the effective date of such termination, as authorized in Attachment "B", plus any profit shown in Attachment "B". Provided, however, if this contract is terminated due to the fault of the Consultant, the provisions of paragraph 25 hereof shall prevail.
27. Designation of Authorized Agent: Under an existing agreement between the MNGWPD and the Atlanta Regional Commission (ARC) certain administrative, financial and technical staff support functions are performed by ARC for the MNGWPD. The following terms apply
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to this contract:
a. ARC shall administer this contract on behalf of the MNGWPD, including but not limited to approval and acceptance of work or services, approval of subcontracts, and authorization of payment.
b. ARC’s Manager, Natural Resources Division is designated as the Authorized Agent for such administration.
28. Georgia Security and Immigration Compliance: The Consultant agrees and hereby
certifies that it will comply with the Georgia Security and Immigration Compliance requirements of O.C.G.A. § 13-10-91.
29. Applicable Law. This contract shall be deemed to have been executed and performed in the State of Georgia, and all questions of interpretation and construction shall be construed by the laws of such State.
30. Notwithstanding any other provision of this agreement, neither party shall have liability to
the other for contingent, consequential, or other indirect damages including, without limitation, damages for loss of use, revenue or profit; operating costs and facility downtime, however the same may be caused. The limitations and exclusions of liability set forth in this agreement shall apply regardless of the fault, breach of contract, tort (including negligence), strict liability or otherwise of Consultant.
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IN WITNESS WHEREOF, the Consultant and MNGWPD have executed this Agreement as of the day first above written.
ATTEST: JACOBS ENGINEERING GROUP
By:
Title:
EIN:
METROPOLITAN NORTH GEORGIA WATER PLANNING DISTRICT
ATTEST:
By: Secretary - Treasurer Chairperson & CEO
ATTACHMENT A
SCOPE OF WORK UPDATE OF THE WATER RESOURCE MANAGEMENT PLAN
General The work to be accomplished by the consultant is in support of the following work program components: Cost Center 003 DPL 2020 Water District Support 003 DDU 2020 Water District Dues 103 DPL 2021 Water District Support 103 DDU 2021 Water District Dues 203 DPL 2022 Water District Support 203 DDU 2022 Water District Dues Overview The purpose of this scope of work is to develop an update to the Water Resource Management Plan (“the plan”) for the Metropolitan North Georgia Water Planning District (“the District”) as required under O.C.G.A. §12-5-570 et seq. The District is the entity responsible for watershed and stormwater management, wastewater management, and water supply and conservation management planning within the 15-county metropolitan area which includes Bartow, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Henry, Paulding, and Rockdale Counties. The District is governed by a 26-member Governing Board made of 16 elected officials and 10 citizen members appointed by the Governor, Lieutenant Governor, and Speaker of the House. The District also includes six Basin Advisory Councils (BACs) to provide a forum for stakeholder input and a Technical Coordination Committee (TCC) made up of staff from local governments across the region. The District last updated and adopted the plan in 2017. The primary objectives of the 2022 plan update are listed below:
1) Using the 2017 plan as a foundation, build on or modify sections that need updating while addressing new requirements as described in this scope of work.
2) Update the plan consistent with Georgia Environmental Protection Division (EPD) guidance, District Governing Board, TCC and BACs guidance and the scope of work detailed below.
3) Advance the District’s on-going approach to integrated water planning. 4) Update the plan with the most current data and information covering a wide range of areas
including water resource management issues, plant capacities, demand projections, etc.
The plan update will be prepared with involvement of local governments, state agencies, the District’s TCC and BACs, other regional water planning councils and other interested stakeholders. The plan update will also build upon and be coordinated with existing planning and regulatory activities. The consultant will be responsible for preparation of the updated data, reports, and materials, at the direction of the District Manager, to support the development of the plan update. The plan is scheduled
2022 Water Resource Management Plan Update Scope of Work
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to be adopted by the District’s Governing Board in December 2022 compliant with the State Water Plan, state water rules, and laws. The following tasks include required activities needed to develop the 2022 Water Resource Management Plan update as well as studies and research that will inform the plan development. Task 1 - Meetings / Stakeholder and Public Involvement The consultant will NOT be expected to attend routine stakeholder meetings of the District Board, TCCs, and BACs. However, the consultant should include the cost to attend 25 stakeholder meetings (does not include meetings described in other tasks) as directed by the District Manager. All meetings will take place within the 15-county District region. The cost for periodic project coordination meetings with District staff should be included in project management costs. The District typically hosts approximately seven meetings of the District Board, TCCs, and BACs each quarter. Deliverables
• PowerPoint presentations summarizing work in progress and discussion items to solicit feedback on consultant deliverables from stakeholders
Assumptions
• The District manager will coordinate meeting announcements, meeting agenda, location, and logistics, as well as meeting summaries and press releases, as needed
Task 2 - Water Resource Management Plan Digital Documents Update and Distribution of Materials The consultant will update the existing digital version of the Water Resource Management Plan, including appendices, and be responsible for final formatting and digital production. The District intends to utilize the existing format and structure in Microsoft Word which will ultimately be saved as an Adobe Acrobat PDF. The consultant should include the same functionality using hyperlinks and bookmarks as the existing PDF file structure found here: https://northgeorgiawater.org/plans-manuals/. The consultant will be provided all text from District staff and will not be responsible for generating new/updated text, charts, or tables except where specifically indicated in the tasks below. District staff will work to prepare a definitions section for the plan, and the consultant will review and provide comments on the definitions. District staff will make updates to the definition section and share with the consultant throughout the plan update process. All consultant work shall use and be consistent with the definitions section. The consultant will provide a technical reviewer to ensure the plan reads in a single voice, provides technical detail in language accessible to the public, uses defined terms correctly and consistently, and contains no errors. All interim reports, milestone materials, drafts and final plans will be delivered to the District Manager in a modifiable digital format to allow printing and posting on the District website and/or distribution via email. Appropriate digital formats include Microsoft Word, Adobe Acrobat PDF, ArcGIS data and all corresponding map project files, as well as supporting Microsoft Excel files. The District will print and publish drafts and final plans as needed. Deliverables
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The deliverables and associated draft plans (five total drafts) will be provided by the Consultant. The review schedule may be refined to help establish an efficient workflow for plan development.
Prepare Preliminary Draft Plan for Committee Review The consultant will be provided initial draft text markups from District staff and will prepare a Preliminary Draft Plan report for review by the District’s Technical Coordinating Committee and Basin Advisory Councils. Prepare Draft Plan for Board Review The consultant will revise the Preliminary Draft Plan and prepare a Draft Plan for review by the District Board. Prepare Draft Plan for Public Comment The consultant will make revisions and modifications requested by the District Board and produce a Draft Plan report for release for public comment. Final Draft Plan Following receipt of comments from the public, the consultant will assist District staff in addressing comments and providing a summary of comments and responses. Based upon these responses, the consultant will revise the Draft Plan and prepare a Final Draft Plan report for the District Board’s consideration. Final Plan Following receipt of any changes made by the District Board, the consultant will prepare a Final Plan report for publication.
Assumptions
• The District Manager will be responsible for consolidating internal comments on each draft of the document
• Final posting on the web site and distribution of the draft documents will be coordinated by the District staff
• The District will be responsible for printing any hard copies
Task 3 - Regional Water and Wastewater Demand Projections The 2017 Plan Update included a major update of water demand and wastewater flow projections across the District. This plan update will evaluate those projections to determine whether any modifications are required based on specific changing conditions within a water or wastewater system. For each county, the consultant shall determine whether a more detailed projection update is required due to changing conditions since 2015. The consultant will start by preparing an updated water and wastewater demands baseline. The baseline will incorporate the most recent available data on population, withdrawals, and discharges. The baseline will include at least a high-level accounting starting with water withdrawals, following each
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major step through the water and wastewater systems (e.g. usage at water plants, imports and exports, non-revenue water, I&I) and uses by major customer classes, and ending with the relative amounts that are consumptively used and those amounts returned to surface waters of each major basin. The consultant should use as its starting point population data from [the US Census Bureau], data collected by EPD through its permitting programs, data submitted by local water providers in their AWWA water loss audit results. As needed, the consultant will work with each utility in the District to obtain water withdrawal and production data and individual meter data for the period since the last plan update and through December 2019 (as possible). It is not anticipated that the meter data will be analyzed for every utility, but instead is being collected such that the next plan update will not require the collection of ten years of data. The consultant will update background spreadsheets with the obtained meter data to be consistent with the prior plan update. The consultant will update and add to (if necessary) the tables and figures in Sections 3.2, 3.3, and 3.4 on existing conditions. District staff will provide the first draft of any text changes to Sections 3.2, 3.3, and 3.4, and the consultant will then review the narrative to double check its technical accuracy. The consultant will review and update, when necessary, county-specific water demand projections in 10-year increments through 2040, which will be used for treatment capacity planning in Appendix B of the plan. An extended forecast will be prepared through 2063, or other long-term date based on OPB’s recent forecast, but given the greater uncertainty inherent in any extended forecast, it will not be used for Appendix B of the plan. Population and employment projection data will be provided to the consultant, potentially from two separate projection sources. In the development of the water demand projections, the consultant will evaluate water withdrawal and production data to determine whether they are generally consistent with the 2017 District plan projections (accounting for variations in climate and economy). The consultant will update and expand the District’s water use profile in the following capacity:
• Update Table and Figures in Section 4, • Update the top down projection approach, which breaks overall water usage by total
consumed/billed, by customer category and by indoor and outdoor use, • Present final water demand projections consistent with Section 4.2.2 and Table 4-7 from the
2017 Plan, and • Perform a regional uncertainty analysis, including factors like changes in commercial and
industrial mix and variations in rainfall and temperature. The consultant will present the draft baselines and projections to each of the 15 counties and the City of Atlanta including all water providers within the county for a minimum of 16 individual county meetings. The consultant will also present the draft results to Georgia EPD staff, the Governing Board, and TCCs and include a minimum of two additional presentations to be determined. The meetings associated with this task are not included in the stakeholder meetings referenced in prior tasks. The baselines and projections may, if necessary, be refined, based on this review, prior to publication in the updated plan. The consultant will prepare county specific wastewater flow projections in 10-year increments through 2040, which will be used for treatment capacity planning in Appendix B of the plan. An extended forecast will be prepared through 2063 but given the greater uncertainty inherent in any extended forecast, it will not be used for Appendix B of the plan. In the development of the wastewater flow projections, the consultant will use the indoor water use component of the water demand projections
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and update and projection methods consistent with the 2017 management plan but refined for current industry practices. In particular, the consultant will evaluate septic system assumptions used during the 2017 plan update to determine if any new utility-specific information needs to be updated. The consultant will update and expand the District-wide and county-specific wastewater projections, including the following from the 2017 Plan: Table 4-8, Table 4-9, and Table 4-10. Deliverables
• Draft data collection tools (e.g. web portals, digital surveys, etc.) • Water and wastewater demand forecast spreadsheets • A draft and final PowerPoint presentation and handouts of each water and wastewater profile
and water and wastewater demand forecasts for each county Assumptions
• Data collection will be performed by the consultant but coordinated with District staff. Task 4 - Planned Water Supply Sources, Drinking Water Treatment Facilities, and Wastewater Treatment Facilities for the Target Year The consultant will review and refine the summary of the water sources identified in Table 5-2 of the 2017 plan for the target year and one intervening year by soliciting input from local water providers. Additionally, the consultant will review and refine the county level summaries of drinking water treatment facilities in Appendix B of the plan by soliciting input from local water providers. New projects not currently included in Appendix B of the plan, and substantive modifications to existing projects will include a brief write-up for each project for Board review. As appropriate, changes to Appendix B of the plan should be made to provide a greater level of specificity of existing, modified, and new projects. For wastewater facilities, the consultant will use the wastewater flows developed in Task 3 and discuss with local wastewater utilities which plants may be new, expanded, or decommissioned. The consultant will use this information to update the summary of future facilities in Appendix B of the plan. This will be performed for both the target year and one intervening year. New projects, not currently included in Appendix B of the plan, will include a brief write-up for each project for Board review. The draft results of this task will be provided to the District and will be reviewed by Georgia EPD, local water and wastewater providers, and the District Governing Board prior to refinement, if necessary and publication in the plan. The consultant will develop a standard template to memorialize the basis of changes made to individual facilities to include the change, who provided the feedback, the rationale for the change, and other pertinent information. Deliverables
• Draft and final PowerPoint presentation and updated tables will be prepared to document the updated list of planned facilities including the updated Appendix B tables and notes on specific facilities. Based on comments, the draft will be revised for review by the TCC and BACs (if necessary). Feedback will be incorporated into the Plan by the consultant.
• Draft and final template for documenting changes to individual utility facilities in Appendix B • Appendix B modifications write-up for District Board review
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Assumptions
• None Task 5 – Biosolids and Residuals Production Projections The consultant will review data gathered by the Georgia Association of Water Professionals (GAWP) 2019 Biosolids Survey and present an existing status of regional biosolids production from municipal wastewater treatment facilities in table format. Based on results from the 2019 survey and target year population and wastewater projections, the consultant will develop a methodology for presenting projected biosolids production in 10-year increments through the target year and present the results of the projections in table form into the plan. In addition, the consultant will gather residuals production data from the District’s water treatment facilities and present an existing status of regional residuals production data in table format. Based on target year water demand projections, the consultant will develop a methodology for presenting residuals production in 10-year increments through the target year and present the results of the projections in table form into the plan. Deliverables
• Draft and final projection methodology • Draft and final PowerPoint presentation and new county level tables • Wastewater treatment biosolids and water treatment residuals demand forecast spreadsheets
Assumptions
• Data collection will be coordinated with District staff. Task 6 - District Stormwater and Watershed Projections The consultant shall prepare a District stormwater and watershed projection for watershed and stormwater management in 10-year increments leading up to 2040 In the development of the projections, the consultant should consider the following key issues and parameters: District population growth, future land use patterns (including new development and redevelopment), impervious cover, mix of grey and green stormwater infrastructure, mix of municipally owned and privately owned stormwater infrastructure, stormwater/watershed policies (current and future), stormwater/watershed regulations (current and future), meteorological trends, funding, and maintenance scenarios. The goal is to identify programmatic changes to support holistic watershed planning and stormwater management for resilience, public safety, and watershed health. The final projections will include next steps for near term (5-year) progress on potential stormwater opportunities, land use scenarios that can be used to inform watershed and stormwater management planning and policy, projections (in dollars over time) for maintenance and infrastructure investment needs, and an evaluation of the connection between land use and watershed management that is specific to the District. Under this task, the consultant will:
1) Perform a literature review of potential concepts to be included in the stormwater projections
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2) Convene a panel of 10-15 national stormwater and planning experts representing a mix of private, public, and non-profit sectors to collaborate on the concepts to be included in stormwater projections. The consultant will solicit feedback through preliminary work groups to prepare for a full panel facilitated planning session.
3) Gather the concepts framed during the expert panel sessions and turn them into guiding principles for the stormwater projections.
4) Combine existing data with the guiding principles to make an actionable foundation for the stormwater projections within the District Plan and present these recommendations to Stormwater TCC members
5) Provide draft language for the Watershed Section of the District Plan to include recommended actions to push the effort forward over the next 5-years.
Deliverables
• Technical memorandum of foundational concepts of stormwater projections including documentation of literature review
• Draft agendas and minutes from expert panel meetings • Presentation of final Guiding Principles for Stormwater Projections and recommended actions to
TCC members • Draft language for the Watershed Section of the District Plan
Assumptions
• None Task 7 - Exploring Localized Demands from New Residential Developments; Estimating Tools District staff has been working with local water providers in the region to collect water use data on new single-family, townhome, and multi-family developments. The goal has been to understand localized examples of the water use profiles of new residential developments in our region. While new water demands from new developments comprise a relatively small share of overall water demand within the District, accurate estimates of these demands are important for local governments and planning at the local scale. This may especially help smaller jurisdictions develop appropriate site-specific estimates of water and wastewater demands from new developments. In coordination with District staff, the consultant will develop a report detailing information on the localized demands from new residential projects in the District of various types, including a range of housing, landscape, and demographic factors. First, the report will include a write-up of all local examples analyzed and an analysis of their indoor and outdoor water use profiles. Second, the report will include a tool for estimating water and wastewater use for new residential developments, a presentation of a generalized range of new residential development types and their expected water use profiles, or some other medium agreed to by District staff that conveys to local water providers what they can expect in terms of water use from new developments in their service areas. The consultant will test the tool with several local water providers to ensure it is easy to use and useful for estimating water use from new developments in their service areas in the future. The consultant will be provided with the data and analysis performed by District staff and will need to have or gain a detailed understanding of the Water Research Foundation’s Residential End Uses of Water, Version 2 (DeOreo et. al. 2016 - Report #4309b). The consultant will review the existing
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analysis, and identify additional data needs related to development types or water use profiles. These data needs will be filled by contacting local water providers for information, or communicating with the development community, as appropriate.
Deliverables • Draft and final Localized Demands from New Residential Developments technical memorandum • Draft and final tool for estimating water and wastewater use for new residential developments
Assumptions
• The District will provide data and analysis previously performed by District staff Task 8 - Drought Response Options Menu The EPD Drought Rule (see DNR Drought Management Rules, Chapter 391-3-30) provides the following levels of drought response: Level 1, Level 2, Level 3, and Level 3+. The drought rule further establishes the general drought response restrictions and strategies under Levels 1, 2, and 3, but EPD has left significant discretion to local water providers on the details of how to implement and enforce these general restrictions and strategies. Local water providers have even more discretion to come up with additional restrictions and strategies under Level 3+. The District would like to preserve this local discretion while providing data-informed and effective options for drought response to local water providers that are looking for ideas on implementing and enforcing the EPD Drought Rule. The primary goal is to present a menu of behavioral and other drought response options that are consistent with the EPD Drought Rule and that will most effectively achieve short-term demand reductions as appropriate for each drought response level. The consultant will create a drought response options menu as a technical resource for water providers with a section dedicated to each of the drought response levels 1, 2, 3, and 3+. The consultant will prepare a draft based upon the education and other drought response materials previously created by District staff, as well as District staff input. The consultant and District staff will present the draft to one joint BAC meeting, one joint water/wastewater/education TCC meeting, and one Governing Board meeting. These meetings are not included in other tasks. The consultant will then prepare a final drought response options menu. The options menu will be based on existing case studies from prior droughts in the District or elsewhere in the US or abroad that include quantitative analyses to measure the effectiveness of specific drought responses whenever possible. Qualitative and other supporting research will also be used and cited as necessary showing why a proposed option is expected to be effective in reducing short-term demands. The consultant will identify areas where further data collection and quantitative analyses may be needed for consideration by the District and other organizations in the future. The consultant will convene a working session of local water providers in the District, or alternatively conduct one-on-one interviews, along with an online survey tool, to get their input from their experience of drought conditions in Georgia over the last 10-15 years, as well as their experience implementing any of the items listed in EPD’s Drought Response Strategies list.
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As part of the options menu, the consultant will include step-by-step instructions on how to implement the options, any needed templates for education campaigns, model policies and ordinances, enforcement options, templates for citations, and other items essential to implementing and enforcing the options. In developing the options menu, the consultant will consider and include:
• A range of local water provider sizes and appropriate/implementable resources for each size as well as variation in customer indoor and outdoor use profiles and subsets of customers who use higher than average amounts
• Seasonal patterns of lawn irrigation use • Education campaigns focused on customers using higher than average amounts of water for
landscape irrigation • Methods to utilize AMI and traditional metering data • Tailored messaging and responses for (1) winter months, (2) the months leading into landscape
irrigation season, and (3) the landscape irrigation season • Water waste policies and their implementation
Deliverables
• Draft and final Drought Response Options Menu with Implementation Activities and Outreach Materials
• PowerPoint presentation for Governing Board, TCC, and BAC meetings Assumptions
• None Task 9 - Watershed Resilience Evaluation The consultant will evaluate opportunities to improve watershed resilience to support long-term water supplies and assimilative capacity across the District. The effort should evaluate the risks associated with extreme weather conditions that may include extended droughts and more intense flood impacts using the 2015 Utility Climate Resilience Study as support. The following elements will be included for evaluation:
1) Tree Ring Analysis and Alternate Water Supplies for Resilience a. Further the work on previous tree ring analysis to include the last 20 years and to tell
the story of the need for watershed resilience in the District. b. Evaluate and identify alternate water supplies that could help build resilience in the
District. Including a subtask on quarries building on the inventory developed by the District. Other possible options could include stormwater capture, IPR/DPR, etc.
c. Utilize a water balance model to test effectiveness of alternate water supplies in two watersheds using previously developed work products from 2015 Utility Climate Resiliency Study.
d. Identify measures to consider for extreme droughts (5-plus years). Potential actions may be detailed under Task 8 or in the development of new actions in the Plan.
2) Risk of Small Withdrawals to Water Supply and Assimilative Capacity - Evaluate the risk of small withdrawals on two watersheds/streams, possibly using the following methodology:
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a. Obtain historical flow for selected streams and evaluate low flow periods and identify 7Q10 flows and time periods.
b. Run statistical analysis using historical low flows and various scenarios of small withdrawals (<100,000 gpd) to evaluate the degree to which small withdrawals may cause adverse effect to the streams’ ability to provide sustainable water supply to reservoirs and to assimilate treated wastewater discharge.
i. Perform a two-day ground truthing survey for up to two watersheds to quantify existing small water withdrawals.
ii. Perform desktop analysis to quantify number of parcels within each basin that may contribute to small withdrawals
c. Summarize results of analysis, compared to existing risk of small withdrawals affecting water supply and assimilative capacity.
3) Leadership Group – Assist, strategize and convene a leadership group of experts to elevate new watershed resilience concepts for the District. Facilitate as requested by the District in identifying and communicating with these experts for a workshop-style event with regional leadership.
Deliverables • Draft and final technical memorandum describing additional tree ring analysis, technical
memorandum summarizing the findings of the alternate water supplies analysis also including quarries subtask and the results of the water balance model analysis
• Draft and final technical memorandum describing the analysis performed for the risk assessment for small withdrawals to include the findings of the statistical analysis on two streams
• Draft and final technical memorandum describing the output of the leadership group workshop
Assumptions • None
Task 10 - Cost-Benefit Analyses - Task Order(s) As directed by the District Manager through one or more task orders, the consultant will perform a cost-benefit analysis (CBA) of new and/or expanded action items in the 2022 plan update and provide a CBA tool for jurisdictions to use when an action item allows for varying levels of effort. Potential new and/or expanded action items will be identified during the 2022 plan update stakeholder process. When requested by the District Manager, the consultant will provide a fee estimate for each CBA. Upon approval, the District Manager will execute a written task order to the consultant authorizing work to begin. The cost-benefit analysis should follow the approved Cost Benefit Framework for the 2022 Plan Update provided in Appendix B of this RFP. Deliverables
• Draft and final cost-benefit spreadsheet and technical memorandum for each task order
2022 Water Resource Management Plan Update Scope of Work
11
• Other items to be determined based on individual task orders Assumptions
• None Task 11 - Water Efficiency, Wastewater, Watershed/Stormwater, and Public Education Action Items Support - Task Order(s) The District desires to maintain its status as a national leader in long-term water resource planning, including practices to enhance water use efficiency. These may include more efficient plumbing fixtures, appliances, and other end use technologies and/or more efficient landscape irrigation system design and operation. Additionally, continuing the District’s focus on management practices that protect water quality and improve asset management are key to maintaining strength in the District’s plan. The District also desires to:
• Eliminate action items when they are both fully duplicative of federal or state requirements and including them in the plan provides no meaningful additional benefits, such as improved implementation and enforcement
• Address out of date action items by either updating them to match current best practices or eliminating them once they have substantially achieved their intended purposes
• Evaluate using population or other thresholds for local governments action items to address smaller local governments, their more limited resources, and their relatively minor impact viewed from a regional scale
The District staff will lead the effort to evaluate existing and potential new water resource and public education and outreach action items. District staff will schedule up to four initial meetings (one per subject area) with the selected consultant to discuss water resource and public education action items. District staff will then prepare an initial evaluation of existing and potential new action items, assign specific work to the consultant to refine the initial evaluation, request specific supporting research, analysis, and reports from the consultant, and make recommendations to the Governing Board, TCCs, and BACs. Through this process, the District Manager will direct the consultant through one or more task orders. When requested by the District Manager, the consultant will provide a fee estimate for the defined task. Upon approval, the District Manager will execute a written task order to the consultant authorizing work to begin. The consultant will make experienced staff available upon request with expertise in various subject areas including, but not limited to:
• Conservation rate design best practices, including residential rates, irrigation rates, and rates for other customers classes
• Premise plumbing, efficient plumbing fixtures, appliances, and other end use technologies • Efficient landscape irrigation system design and operation • Water loss and knowledge of AWWA Water Audit process • Water and wastewater utility master planning • Water and wastewater asset management
2022 Water Resource Management Plan Update Scope of Work
12
• Wastewater biosolids management • Wastewater reuse • Septic management • Stormwater management practices and design criteria • Stormwater master planning and condition assessment • State and/or Federal requirements • Land use planning measures • Funding strategies / stormwater utilities • Public education and outreach best practices • Equity in relation to water/wastewater/watershed/education actions
In addition to providing support to the District regarding the work above, the District may also work with the consultant on a task order basis to document the successes of the District over the 20-year history since its formation in 2001. Furthermore, the District may request on a task order basis that the consultant help to provide a history of the District foundation and early years. Deliverables
• To be determined based on individual task orders Assumptions
• None
2022 Water Resource Management Plan Update Scope of Work
13
J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J A S O N DNotice to ProceedMeetings and Stakeholder Involvement PeriodTechnical Support TasksPreparation of PlanPublic Comment PeriodPlan to GA EPD for ApprovalFinal Plan for Governing Board Approval
2023
2022 Water Resource Management Plan Update Schedule
2020 2021 2022
2022 Water Resource Management Plan Update
ATTACHMENT B
COMPENSATION AND METHOD OF PAYMENT
I. Compensation: The total compensation to be paid by the Metro Water District to the Contractor for the Project as described in "Attachment A" is $875,000 ($635,000 lump sum plus $240,000 for task orders approved by the Metro Water District’s Project Manager and District Chairman). A breakdown of this compensation is shown in Exhibit B-1, "Contract Budget", which is attached to and made part of this contract for financial reporting, monitoring and audit purposes. II. Method of Payment: The following method of payment replaces that specified in the main body of the contract. A. Progress Payments: The Contractor shall be entitled to receive progress payments on the following basis. As of the last day of each month during the existence of this contract, the Contractor shall submit to the Metro Water District an invoice for payment documenting work performed during the invoice period. Any work for which payment is requested may be disallowed at the Metro Water District’s discretion if not properly documented, as determined by the Metro Water District, in the required monthly narrative progress report. Upon the basis of its audit and review of such invoice and its review and approval of the monthly reports called for in the paragraph concerning “Reports” in the main body of the contract, the Metro Water District will, at the request of the Contractor, make payments to the Contractor as the work progresses but not more often than once a month. Invoices shall be numbered consecutively and submitted each month until the project is completed. The Contractor’s monthly invoices and monthly narrative progress reports are to be submitted to the Manager of the Metro Water District or his authorized agent and must be received by him not later than the 15th day of the following month. The Metro Water District may, at its discretion, disallow payment of all or part of an invoice received after this deadline. B. Final Payment: Final payment shall only be made upon determination by the Metro Water District that all requirements hereunder have been completed. Upon such determination and upon submittal of a final invoice, the Metro Water District shall pay all compensation due to the Contractor, less the total of all previous progress payments made. The Contractor's final invoice and final narrative progress report must be received by the Metro Water District no later than 15 days after the project completion date specified in Paragraph 2 of the contract. The Metro Water District may, at its discretion, disallow payment of all or part of a final invoice received after this deadline. III. Completion of Project: It is agreed that in no event will the maximum compensation and reimbursement, if any, to be paid to the contractor under this contract exceed $875,000 and that the contractor expressly agrees that he shall do, perform and carry out in a satisfactory and proper manner, as determined by the Metro Water District, all of the work and services described in Attachment A. IV. Access to Records: The contractor agrees that the Metro Water District, the Concerned Funding Agency or Agencies and, if appropriate, the Comptroller General of the United States, or
2022 Water Resource Management Plan Update
any of their duly authorized representatives, shall have access to any books, documents, papers and records of the contractor which are directly pertinent to the project for the purpose of making audit, examination, excerpts and transcriptions. The contractor agrees that failure to carry out the requirements set forth above shall constitute a breach of contract and may result in termination of this agreement by the Metro Water District or such remedy as the Metro Water District deems appropriate.
2022 Water Resource Management Plan Update
EXHIBIT B-1
CONTRACT BUDGET
Task Item Budget ($)
Task 1 - Meetings / Stakeholder and Public Involvement $ 66,000 Task 2 - Water Resource Management Plan Digital Documents Update and Distribution of Materials $ 27,000 Task 3 - Regional Water and Wastewater Demand Projections $ 165,000 Task 4 - Planned Water Supply Sources, Drinking Water Treatment Facilities, and Wastewater Treatment Facilities for the Target Year $ 32,000 Task 5 - Biosolids and Residuals Production Projections $ 46,000 Task 6 - District Stormwater and Watershed Projections $ 100,000 Task 7 - Exploring Localized Demands from New Residential Developments; Estimating Tools $ 40,000 Task 8 - Drought Response Options Menu $ 59,000 Task 9 - Watershed Resilience Evaluation $ 100,000
Lump Sum Tasks Total $ 635,000
Work completed under the following tasks will be subject to approval on an individual task order basis. No work should be performed without written approval from the District's project manager. The following budget amounts reflect the available budget and are not guaranteed amounts. Task 10 - Cost-Benefit Analyses [Task Order(s) - Total Not to Exceed] $ 40,000 Task 11 - Water Efficiency, Wastewater, Watershed/Stormwater, and Public Education Action Items Support [Task Order(s) – Total Not to Exceed] $ 200,000
Task Order Budget Total $ 240,000
Total Contract Amount $ 875,000
Note: The estimates for Tasks 1-9 listed above are preliminary and actual costs by task may vary so long as the total contract value does not increase. Any change to the budget estimates shown above must be requested in writing and approved by the Metro Water District Project Manager.
Cost Center Distribution: $550,000 003DPL, 103DPL, 203DPL (To be expended first) $325,000 203DDU (To be expended last)
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